| name | breach-purchase-complaint |
| title | Complaint for Breach of Purchase Agreement |
| description | Drafts a state-court complaint for breach of a real property purchase agreement. Triggers when the user needs to initiate a lawsuit for breach of a real estate purchase contract, purchase agreement breach, or buyer/seller contract dispute. Covers caption, jurisdiction/venue, party allegations, chronological facts, contract elements, damages, and prayer for relief. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/breach-purchase-complaint |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | real-estate |
| language | en |
| tags | ["drafting","litigation","pleading"] |
Complaint for Breach of Purchase Agreement
Generates a filing-ready complaint alleging breach of a real property purchase agreement with jurisdiction-specific formatting and element-driven pleading.
Prerequisites
Collect before drafting:
- Executed purchase agreement — all addenda, amendments, exhibits
- Party details — full legal names, entity types, formation states, registered agents, addresses
- Breach documentation — correspondence, notices, cure demands, performance timeline
- Damages evidence — closing costs, market values, mitigation expenses, consequential losses
- Court/jurisdiction — target court, local rules, formatting requirements
Workflow
1. Caption
Include court name (division/department), blank case number, full party names with entity designations, and title "COMPLAINT FOR BREACH OF PURCHASE AGREEMENT." Format per local rules.
2. Jurisdiction & Venue
- State subject-matter jurisdiction basis (amount in controversy or statutory grant)
- Address any forum-selection or choice-of-law clauses in the agreement
- Tie venue to property location, contract execution location, or defendant's residence/principal place of business
- Cite jurisdictional statute (long-arm if applicable)
3. Parties
Allege for each party: full legal name, address, entity type and formation state (if applicable), role in the agreement (buyer/seller/assignee), and any DBAs. For entity defendants, include registered agent.
4. Factual Allegations
Structure as numbered paragraphs in chronological order:
- Formation — execution date, property (address, APN, legal description), price, payment terms
- Material terms — contingencies, closing date, inspection periods, financing, special provisions
- Plaintiff's performance — obligations met, payments made, conditions satisfied (dates and amounts)
- Defendant's breach — specific unperformed obligations, breach date, notice given, cure opportunity
- Post-breach — communications, failed cure, mitigation efforts
Quote exact contract language for breached provisions. Use specific dates, amounts, and document references.
5. Cause of Action
Plead each element with cross-references to factual paragraphs:
