Vincenzi v. Cerro
Connecticut Supreme Court
442 A.2d 1352 (1982)
Vincenzi (plaintiff) contracted to build Cerro (defendant) a house for $91,000, paid in five installments; Cerro paid the first four but refused the final installment, claiming the house wasn't complete. Vincenzi sued for the remaining amount, and Cerro counterclaimed for the cost of incomplete or defective work. The trial court found the work substantially complete despite some minor unfinished items, entering judgment for Vincenzi for the balance less $5,000 for incomplete or defective work, and Cerro appealed, arguing Vincenzi's willful failure to finish all required work barred the substantial-performance doctrine entirely.
Whether a party who is guilty of a willful breach of contract is prohibited from recovering for that party's substantial performance on the contract.