Misipeka v. Legislature of American Samoa

7 Am. Samoa 3d 96
CourtHigh Court of American Samoa
DecidedMay 5, 2003
DocketCA No. 05-03
StatusPublished

This text of 7 Am. Samoa 3d 96 (Misipeka v. Legislature of American Samoa) is published on Counsel Stack Legal Research, covering High Court of American Samoa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Misipeka v. Legislature of American Samoa, 7 Am. Samoa 3d 96 (amsamoa 2003).

Opinion

ORDER GRANTING PLAINTIFF ÁND DENYING DEFENDANT SUMMARY JUDGMENT

Before us are cross-motions for summary judgment. We grant plaintiffs motion and deny defendant’s motion.

[98]*98I. BACKGROUND

Plaintiff Kelemete Misipeka (“Misipeka”) is a resident of American Samoa. He is in the business of supplying sound systems. In the past, he has worked for the Teuila and Mosooi Festivals, the 1997 South Pacific Mini-Games, and the 1998 Miss Americans Samoa Pageant. In 1998, Misipeka provided sound system services to Defendant Legislature of American Samoa (“Legislature”) for the festivities of the Fono ■ Golden Jubilee held in honor of the Legislature’s 50th anniversary. He purportedly made an oral agreement with Senator Moaali'itele Tu'ufuli (“Senator Moaali'itele”), the Chairman of the Fono Golden Jubilee Committee.

The festivities spanned six days and included performers of all types. Misipeka was responsible for accommodating the various audio applications including instrumental hook-ups, extra speakers and special microphones. Additionally, Misipeka assisted KVZK, the local television provider, in broadcasting both live and recorded television feeds.

After the festivities ended, Misipeka sent a detailed invoice to Senator Moaali'itele. The total amount due was for $33,090. On October 30, 1998, the invoice was initialed and approved for payment by Senator Moaali'itele. Legislative Financial Officer, Velega Savali certified payment on October 21, 2002. Despite the seeming approval of Misipeka’s invoice, he was not paid. He contacted the Legislature and numerous attempts were made to settle the matter. These efforts, however, were to no avail; the Legislature, for one reason or another, refused to pay Misipeka for his services.

Understandably, after years of hying to collect, Misipeka’s frustration pushed him to file this suit. Normally, this would be a simple contract dispute ripe for resolution. However, it is complicated by one glaring defect. The original contract between Misipeka and the Legislature — • specifically with Senator Moaali'itele, as chairman of the Jubilee committee — was not put in writing. The only writing evincing any agreement is the invoice Misipeka subsequently sent to the Legislature.

Both parties have moved for summary judgment. The Legislature, in seeking to avoid payment, argues that the only agreement that existed, if any, was the verbal agreement between Senator Moaali'itele and Misipeka. If true, the consequence of such an agreement would be dismissal of the suit because the statute of limitations has run. See A.S.C.A. § 43.0120(3) (three year statute of limitation on unwritten contracts). In the alternative, the Legislature posits that even if there was a written agreement, the only officers that can bind the Legislature are the President of the Senate and the Speaker of the House (“the binding [99]*99officers”). Neither of the binding officers, however, signed or initialed Misipeka’s invoice.

Misipeka, on the other hand, argues that the invoice he sent, initialed and approved by Senator Móáali'itele (and Velega Savali), constitutes a written contract that extends the statute of limitations to 10 years. See A.S.C.A. § 42.0120(5). Furthermore, Misipeka contends that it is possible to contract generally with the Legislature through agents other than the binding officers. Indeed, he responded to the solicitation on behalf of the Legislature, generally, and Senator Moaali'itele, as Chairman of the Jubilee Committee, specifically, for his sound system services.

XL STANDARD

Summary judgment is appropriate when there is “no genuine issue as to any material fact.” T.C.R.C.P. 56(c); Plaza Dep’t Store v. Dunchnak, 26 A.S.R. 2d 82, 83 (Trial Div. 1994). The pleadings and supporting documents are viewed in the light most favorable to the non-moving party. See Amerika Samoa Bank v. United Parcel Serv., 25 A.S.R.2d 159, 161 (Trial Div. 1994); Ah Mai v. Am. Samoa Gov’t (Mem.), 11 A.S.R.2d 133, 136 (Trial Div. 1989). Furthermore, as in this case, “disputed ‘legal questions .. . present nothing for trial and [are] appropriately resolved on a motion for summary judgment.’” Flair Broad. Corp. v. Powers, 733 F. Supp. 179, 184 (S.D.N.Y. 1990) (quoting Holland Indus. v. Adamar of New Jersey, Inc., 550 F. Supp. 646, 648 (S.D.N.Y. 1982)).

m. DISCUSSION

A. Written or Unwritten Contract

The cmx of this case comes down to one question: was the contract between Misipeka and the Legislature written or unwritten? The importance of this question derives from our statutes of limitations: oral, or unwritten, contracts carry with them a three-year statute of limitations, A.S.C.A. § 43.0120(3), as opposed to written contracts, which can be enforced within 10 years after the action accmes, A.S.C.A. § 43.0120(5). See generally Pene v. Bank of Hawaii, 17 A.S.R.2d 168, 170 (App. Div. 1990). Because any contract between the parties was reached approximately five years ago, if it was merely an oral agreement, the suit is subject to dismissal but if it was written, the suit can proceed.

While the definition of a written contract would seem straightforward, applying it to various situations can be difficult. A written contract, for purposes of the statute of limitations, is one “containing all the terms of a completed contract between the two parties [and] is executed by one of the parties and accepted or adopted by the [100]*100other.” Id. at 171, (citing 3 A.L.R.2d 809, 819 (1949)). Put another way, “[a] written contract, is one which is all in writing, so that all its terms and provisions can be ascertained from the instrument itself.” Id. (quoting Mills v. McGaffee, 254 S.W.2d 716, 717 (Ky. 1953)); see Clark v. Robert W. Baird Co., Inc., 142 F. Supp. 2d 1065, 1075 (N.D. Ill. 2001); Empire Land Title v. Weyerhaeuser Mortgage, 797 P.2d. 467, 469 (Utah App. 1990); Urban Dev., Inc. v. Evergreen Building Prods., L.L.C., 59 P.3d 112, 119 (Wash. 2003).

In the instant case, we need not go beyond the invoice itself to determine “the essential elements of the contract, which include the subject matter, parties, terms and conditions, and price or consideration.” Urban Dev., Inc., 59 P.3d at 119; see Empire Land Title, 797 P.2d at 469. But see Clark, 142 F. Supp. 2d at 1075 (no contract because parole evidence necessary to establish terms of contract). The invoice in this case clearly defines the parties to the contract — Misipeka and the Legislature; both parties signed the contract; the contract was for services rendered at the Jubileé; Misipeka was to provide the sound system for the events of the entire six days; and the price of the services is meticulously documented.

The Legislature raises two points in opposition. First, it notes that the document was signed after the event took place and after the services were rendered. However, “a memorandum that memorializes an oral agreement between the parties satisfies the writing requirement” for purposes of the statute of limitations. Urban Dev., Inc., 59 P.3d at 119; see Evans v. Pickett Bros. Farms, 499 P.2d 273, 275 (Utah 1972); cf. Am.

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Related

Holland Industries, Inc. v. Adamar of New Jersey, Inc.
550 F. Supp. 646 (S.D. New York, 1982)
Flair Broadcasting Corp. v. Powers
733 F. Supp. 179 (S.D. New York, 1990)
Clark v. Robert W. Baird Co., Inc.
142 F. Supp. 2d 1065 (N.D. Illinois, 2001)
Claxton v. Mains
514 N.E.2d 427 (Ohio Court of Appeals, 1986)
Mills v. McGaffee
254 S.W.2d 716 (Court of Appeals of Kentucky, 1953)
Empire Land Title, Inc. v. Weyerhaeuser Mortgage Co.
797 P.2d 467 (Court of Appeals of Utah, 1990)
Evans v. Pickett Bros. Farms
499 P.2d 273 (Utah Supreme Court, 1972)

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Bluebook (online)
7 Am. Samoa 3d 96, Counsel Stack Legal Research, https://law.counselstack.com/opinion/misipeka-v-legislature-of-american-samoa-amsamoa-2003.