Wayment v. Schneider Automotive Group LLC

438 P.3d 1005 (2019)

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Nature of the Case

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Facts

P, a professional golfer, played in a charity golf tournament sponsored, in part, by D. Rule sheets, which described the tournament format and identified a hole-in-one contest at the eighth hole, were placed on the participants' golf carts. When golfers arrived at the eighth hole, they saw a new 2015 Subaru XV Crosstrek parked next to the tee box along with a sponsorship sign with D's name and logo. Neither the rule sheet nor the sign stated that the Subaru, or any other prize, would be awarded. P made a hole in one at the eighth hole. After holing the shot, Wayment believed he won the Subaru based on the tournament rule sheet indicating the contest on the eighth hole, D's sponsorship of the hole, and the parked car. Several days after the tournament, D discovered that P was a professional golfer and refused to deliver the car. The tournament organizer did not expect professional golfers to compete for tournament prizes without disclosing their professional status, which P never did. And although that condition was never communicated to the tournament participants, the insurance policy that D procured for the tournament required that the hole-in-one be made by an amateur. P sued D for breach of contract. He claimed that he had accepted D's unilateral offer to give him the car when he made the hole in one. D maintained that professional golfers were excluded from the contest. Each side obtained opinions from professional golfers about whether it was reasonable for P to believe he was eligible to win the Subaru under the circumstances. P and another professional golfer opined that nothing in the custom or rules of the golf community bars professionals from winning prizes in charity golf events. The club pro from the tournament disagreed. He expressed his opinion that, as a matter of custom, professional golfers should disclose their professional status before playing in golf events with amateurs. He also opined that it is generally understood in the golf community that professional golfers are not eligible for competition prizes unless the competition rules explicitly say otherwise. P moved for summary judgment on his breach of contract claim, which the district court granted. The court concluded it was 'reasonable for participants to think that they could win a car by making a hole-in-one . . . if they were an amateur.' The court then concluded that because D did not manifest its subjective intent to limit the contest to amateur golfers, it was reasonable for P, as a professional golfer, to believe he was eligible to win the Subaru. D appealed.