New Hampshire Superior Court - 6 N.H. 481
In the 1834 case Britton v. Turner, the New Hampshire Supreme Court tackled a labor contract dispute. The dispute ended up at the highest state court after a lower court ruled in favor of the employee, Britton, who had left his job before the end of his one-year term. The employer, Turner, refused to pay Britton for his work, so Britton sued under the principle of quantum meruit, or reasonable value for services rendered.
At issue was whether Britton could be compensated for his work, even if he hadn't fully completed his contract obligations. The court ruled that Britton could recover under the doctrine of quasi-contract, a legal idea that requires a party to compensate another for benefits received, even without a formal contract between them. The court felt it would be unfair to deny Britton any pay, as his work had benefited Turner more than the damages caused by his contract breach.
This case is significant for its demonstration of how courts use quasi-contract to prevent unfair outcomes when a contract is breached. It also highlights how courts weigh the interests of both parties in contract disputes to avoid harsh or unreasonable results. The case is an early example of the concept of guilty party restitution, meaning that a contract-breaching party can still recover for their performance, minus any damages caused by the breach.
The court ruled that the plaintiff cannot recover the full amount for a special contract if the service was not fully performed, but may recover a reasonable sum for the work already done under quantum meruit. The technical rule requiring full performance for compensation can be unjust, and a party who breaches a contract may still be required to pay a reasonable amount for labor and materials provided. If a party benefits from work performed, they should pay the reasonable worth of what has been done for their benefit. If a buyer discovers inferiority in goods after using them, they can claim the price or keep the goods if canceling the contract is impractical. The seller cannot recover more than the benefits the buyer has gained from the goods. If a buyer receives a partial delivery, they must pay for the received portion. If a party accepts partial performance, they can recover damages suffered due to the other party's failure to fulfill the contract. The party responsible for the service cannot recover payment if they fail to fulfill the special contract and the money is not yet due, unless the other party has received and benefited from what has been done. The law will not imply a different contract than the one agreed upon by the parties, unless there is further agreement between them.
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