to perform the service skillfully, carefully, diligently, and in a workmanlike manner.” Fed. Ins. Co. v. Winters, 354 S.W.3d 287, 292 (Tenn.2011) (collecting cases); see also Herbert A. Sullivan, Inc. v. Utica Mut. Ins. Co., 439 Mass. 387, 788 N.E.2d 522, 531 (2003) (“When a party binds himself by contract to do a work or to perform a service, he agrees by implication to do a workmanlike job and to use reasonable and appropriate care and skill in doing it.”) (citation and internal quotation marks omitted); Davis v. New England Pest Control Co., 576 A.2d 1240, 1242 (R.I.1990) (“[T]here is implied in every contract for work or services a duty to perform it skillfully, carefully, and diligently and in a workman-like manner[.]”); Archibald v. Act III Arabians, 755 S.W.2d 84, 85 (Tex.1988) (<HOLDING>). As the Mitchells further point out, courts
holding that the plaintiff had offered insufficient evidence to establish deliberate indifference in a failuretotrain claim in part because the plaintiff did not present evidence that the training received was inadequate or evidence of any specific additional training that the employees should have received recognizing an implied warranty in horse training because training introduces new elements to enhance the horses capabilities and personality and extinguishes undesirable traits holding the implied warranty is implied in all residential leases in california holding that ems training lieutenants position met criteria because the lieutenants developed coordinated implemented and conducted ems training programs  prepared lesson plans and training aids supervised delivery of training and tests and evaluated new equipment holding experts experience knowledge and training is considered in determining reliability