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Broughton v. Johnson

The trial court erred in precluding defendant from presenting evidence of her relationship with the decedent to demonstrate that his services during the construction of her house were gratuitous.

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Lenorris Johnson, as administrator of the estate of Arthur James Johnson, Sr., sued Vickie D. Broughton for costs and other damages associated with building a house. Johnson claimed that the decedent acted as general contractor during the construction of Broughton’s house and that Broughton wrongfully refused to pay for his services. Johnson moved the trial court to exclude evidence of a three-and-one-half-year affair between the decedent and Broughton, claiming that their “adulterous and/or fornicatious relationship” was immaterial to any issue presented in the case. The trial court granted the motion, excluding from evidence any reference to the relationship between the decedent and Broughton on the basis that it is “irrelevant and immaterial to any legal defense” available to Broughton. Broughton filed an interlocutory appeal from its order, which this Court granted. Because we find that the evidence of a relationship between Broughton and the decedent is relevant to certain issues presented, we reverse the trial court’s order.

In his complaint, Johnson asserted that the estate was entitled to recover for breach of contract or, in the alternative, quantum meruit. Broughton answered and denied that any contract existed between her and the decedent. Broughton also denied liability under quantum meruit.

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