The U.S. Court of Appeals for the Seventh Circuit has upheld a jury's verdict in a breach of contract case involving Indeck Power Equipment Company and Ashley Energy LLC. The court ruled on October 27, 2026, that while Ashley breached the lease agreement by damaging a boiler, Indeck failed to prove it suffered any damages as a result. This decision is significant as it highlights the importance of demonstrating actual damages in breach of contract claims.

The case, filed under docket number 26-1390, arose from a lease agreement between the two companies regarding a boiler and related equipment. The ruling impacts both companies and sets a precedent regarding the burden of proof in contract disputes.

Background

Indeck Power Equipment Company, a boiler leasing company, entered into a lease agreement with Ashley Energy LLC in January 2020. Ashley, an energy company servicing the St. Louis area, needed to rent a boiler after experiencing severe flooding that damaged its equipment. The lease required Indeck to provide a “like-new” boiler and a new water treatment trailer, while Ashley was responsible for maintaining the equipment and following industry guidelines.

After the boiler was delivered and installed, issues arose during the start-up phase, particularly with malfunctioning flowmeters that affected the water quality entering the boiler. Despite these issues, Ashley returned the boiler in April 2020, after which Indeck discovered significant scale buildup inside the boiler. This led Indeck to file a lawsuit against Ashley, claiming breach of contract and seeking over $3 million in damages.

The Ruling

After a five-day trial, the jury found that while Indeck had performed its obligations under the contract and Ashley had breached the lease, it did not find sufficient evidence that Indeck had sustained damages due to Ashley's breach. The jury's verdict indicated that the damage to the boiler did not exceed normal wear and tear.

The court ruled, "a finding that Plaintiff performed under the contract does not necessarily mean that the jury also found that any damage was caused by Defendant or even constituted damage beyond normal wear and tear."

Indeck subsequently filed a motion for a new trial, arguing that the jury's verdict was against the manifest weight of the evidence and constituted a compromise verdict. However, the district court denied this motion, stating that the jury's determination was supported by sufficient evidence.

Impact

This ruling underscores the necessity for plaintiffs in breach of contract cases to provide clear evidence of damages resulting from the breach. The court's affirmation of the jury's verdict means that even if a breach is established, without proof of damages, the plaintiff may not receive compensation. This case serves as a reminder for businesses to maintain thorough documentation and evidence of damages when pursuing legal action for contract breaches.

Furthermore, the ruling clarifies that even when a breach is acknowledged, the absence of demonstrable harm can prevent recovery of damages. This could influence future contract disputes, as parties may be more diligent in ensuring they can substantiate claims of damages.

What's Next

Indeck Power Equipment Company has the option to appeal the ruling, but it remains uncertain whether they will pursue further legal action. There are currently no related cases pending that have been mentioned in the court filings.