Enhanced Prompt: Complaint for Breach of Contract

You are tasked with drafting a comprehensive Complaint for Breach of Contract, a formal litigation document that initiates a civil lawsuit. This complaint must be professionally structured, legally sound, and tailored to the specific facts of the case while adhering to applicable procedural rules and substantive law.

Understanding the Assignment

Begin by thoroughly reviewing all uploaded documents related to this matter. Extract and analyze the underlying contract, correspondence between parties, evidence of performance or breach, damage calculations, and any other relevant materials. Your goal is to understand the complete factual narrative: how the contract was formed, what obligations each party undertook, how the plaintiff performed their duties, how the defendant failed to perform, and what harm resulted from that failure.

Drafting the Caption

The caption establishes the formal framework of the lawsuit. Include the full name of the court (with proper designation of division or department if applicable), the case number if one has been assigned, and the complete legal names and capacities of all plaintiffs and defendants. Research the specific caption format requirements for the jurisdiction where this complaint will be filed, as courts have precise formatting expectations. State courts, federal district courts, and specialized tribunals each maintain their own conventions for case styling, and compliance with local rules is essential for proper filing.

Crafting the Introduction

Open with a clear, concise statement identifying this as an action for breach of contract. Establish the court's subject matter jurisdiction by explaining the legal basis for the court's authority to hear this dispute—whether diversity jurisdiction, federal question jurisdiction, or state court general jurisdiction. Identify the amount in controversy if jurisdictionally relevant. State why venue is proper in this particular court by referencing the defendant's residence, where the contract was to be performed, where the breach occurred, or other venue-establishing facts. This section should be direct and authoritative, immediately orienting the court to the nature and scope of the dispute.

Identifying the Parties

Provide complete identifying information for each party. For individuals, include full legal names, addresses, and their role in the contract (buyer, seller, service provider, etc.). For business entities, specify the exact legal form (corporation, LLC, partnership), state of organization, principal place of business, and registered agent information. Explain each party's relationship to the contract and their standing to sue or be sued. If any party is appearing in a representative capacity (executor, trustee, guardian), clearly state that relationship and the authority under which they act.

Establishing Jurisdiction and Venue

Provide a detailed legal and factual basis for the court's jurisdiction. For federal courts, explain whether jurisdiction arises under diversity of citizenship (citing complete diversity and amount in controversy exceeding $75,000) or federal question jurisdiction. For state courts, identify the statutory or constitutional grant of jurisdiction. Address venue by explaining the connection between the forum and the dispute—where the defendant resides or does business, where the contract was executed or to be performed, where the breach occurred, or where the plaintiff suffered damages. Research and cite the specific jurisdictional statutes and venue provisions that authorize this court to hear this case.

Presenting the Factual Background

Develop a chronological, compelling narrative of the events giving rise to this lawsuit. Begin with how the parties came into contact and negotiated the contract. Describe the contract formation with specificity: when and where it was executed, what consideration was exchanged, and what essential terms were agreed upon. Detail the plaintiff's performance of their contractual obligations, providing dates, amounts, deliverables, or services rendered as applicable. Then describe the defendant's breach with equal specificity—what obligation was not performed, when the breach occurred, whether any notice or opportunity to cure was provided, and how the defendant responded or failed to respond. Use concrete facts drawn from the documents, including specific dates, dollar amounts, communications, and actions. This narrative should be factual rather than argumentative, but should clearly establish the story that supports your legal claims.

Alleging the Cause of Action for Breach of Contract

Structure this section around the essential elements of a breach of contract claim under applicable law. First, allege the existence of a valid and enforceable contract, identifying the parties, subject matter, consideration, and mutual assent. Second, allege the plaintiff's performance of all conditions precedent and contractual obligations, or alternatively, that performance was excused or waived. Third, allege the defendant's material breach of the contract, specifying which provisions were violated and how. Fourth, allege that the breach caused damages to the plaintiff. Research the specific elements required in your jurisdiction, as some states have additional requirements or particular pleading standards. Consider whether any affirmative defenses might be anticipated and whether your allegations should preemptively address them. If the contract contains specific provisions relevant to breach (notice requirements, cure periods, liquidated damages clauses, attorney's fees provisions), incorporate those into your allegations.

Specifying Damages and Relief Sought

Itemize with precision the damages suffered by the plaintiff as a direct and proximate result of the defendant's breach. Include compensatory damages calculated based on the contract terms and actual losses sustained. If consequential damages are sought, allege facts showing they were foreseeable at the time of contracting. Consider whether specific performance or injunctive relief is appropriate and legally available. Request pre-judgment and post-judgment interest at the applicable statutory or contractual rate. Seek costs of suit and, if the contract or statute provides for it, attorney's fees. If punitive damages are available under your jurisdiction's law for breach of contract (rare but possible in cases involving fraud or bad faith), consider whether the facts support such a claim. The prayer for relief should be comprehensive, including both specific amounts where calculable and general damages where appropriate, along with a catch-all request for "such other and further relief as the Court deems just and proper."

Including Procedural Requirements

If a jury trial is desired and available for breach of contract claims in your jurisdiction, include a clear demand for jury trial. Research whether your jurisdiction requires this demand in the complaint or permits it to be made separately. Verify any specific timing or formatting requirements for jury demands. Ensure the complaint includes all required certifications, verifications, or affidavits. Some jurisdictions require the attorney to sign and certify that the pleading is well-grounded in fact and law. Others may require the plaintiff to verify the complaint under oath. Research and comply with all such requirements to avoid procedural defects.

Professional Standards and Best Practices

Throughout the complaint, maintain a professional, objective tone. Avoid inflammatory language, personal attacks, or excessive rhetoric. Use clear, direct sentences and organize information logically. Number paragraphs consecutively for easy reference. Ensure all factual allegations are supported by evidence in your possession. Comply with all applicable rules of civil procedure, local court rules, and ethical obligations regarding pleading standards. Remember that under federal and most state rules, you must have a good faith basis for all factual allegations and legal contentions.

Final Document Creation

Once you have gathered all necessary information from the uploaded documents, researched applicable legal standards and procedural requirements, and organized the factual and legal content, create a polished, professional Complaint for Breach of Contract. The document should be formatted appropriately for court filing, with proper spacing, margins, and typography. Include a signature block for the attorney of record with bar number, firm name, address, telephone, and email. Ensure the document is complete, accurate, and ready for review by the supervising attorney before filing.