The Delaware Superior Court has upheld a decision awarding attorney’s fees and prejudgment interest to Spud Cleaning and Restoration, Inc. in its dispute with Manna Academy Corp. The court ruled on November 2, 2026, affirming a previous ruling that found Manna in breach of contract for failing to pay for restoration services. The outcome is significant for businesses involved in contractual agreements, as it reinforces the enforceability of fee-shifting clauses and the awarding of interest on unpaid amounts.
The case, Manna Academy Corp. v. Spud Cleaning and Restoration, Inc. (C.A. No. N25A-02-007 SSA), began when Manna Academy contracted Spud Cleaning to provide restoration and cleaning services for flood damage at its business location in September 2021. After Spud completed the work, Manna failed to pay the agreed amount, leading Spud to file a breach of contract claim in the Court of Common Pleas. In a ruling on January 22, 2025, the court found that a valid contract existed and that Manna was in breach, awarding Spud $52,844.14.
Following the judgment, Spud sought additional costs, attorney’s fees, and prejudgment interest, totaling $15,603.88 in fees. Manna opposed this request, arguing that the interest was unconscionable and that the fees were unreasonable. A hearing was held where Manna questioned the breakdown of costs and fees, but the trial court found the submissions adequate and awarded the requested amounts. Manna then appealed the decision to the Superior Court, seeking to overturn the award.
The Superior Court reviewed the case and upheld the trial court’s decisions regarding both the attorney’s fees and the prejudgment interest. The court noted that Manna had not preserved its arguments regarding the reasonableness of the fees or the trial court’s review process. The court stated, “Manna cannot maintain that the trial court ‘underst[ood] it [as] an argument that must be considered and decided.’” The judge emphasized that Manna had agreed to the hourly rate of Spud’s counsel, which was deemed reasonable, and that no objections were raised during the initial hearing.
Furthermore, the court found that the trial court acted within its discretion when it awarded prejudgment interest. The court explained that interest is generally awarded as a matter of right, and Manna’s claims of delay did not constitute an inordinate delay that would negate the interest. The ruling stated, “Interest is awarded … as a matter of right and not of judicial discretion.” The court also clarified that the damages did not need to be liquidated for interest to be awarded, as long as they were calculable.
The implications of this ruling are significant for businesses and individuals engaged in contractual relationships. The decision reinforces the importance of adhering to contractual obligations and the potential consequences of failing to do so, including the awarding of attorney’s fees and interest. It also highlights the necessity for parties to clearly articulate their objections during trial proceedings to preserve those arguments for appeal.
Looking ahead, Manna Academy may consider further legal options, including a potential appeal to a higher court. However, the Superior Court’s ruling stands as a strong affirmation of the trial court’s decisions. This case serves as a reminder for businesses to ensure compliance with contractual terms and to be prepared for the financial implications of any disputes that may arise.
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