New York Court of Appeals - 230 N.Y. 239
In Jacob & Youngs, Inc. v. Kent (1921), the New York Court of Appeals dealt with a dispute over a contract for building a house. The homebuilder (plaintiff) argued that it had completed the work as required, with only a small change - using a different type of pipe than specified. The homeowner (defendant) didn't want to pay, claiming that the wrong pipe was a breach of contract, and wanted the correct pipe to be installed, even if it meant significant reconstruction.
The court had to decide if the homebuilder could still be paid despite the pipe issue or if the homeowner could demand a perfect, exact completion or cancel the contract. The court sided with the homebuilder, allowing them to collect the payment, minus any damages caused by using the different pipe. The court used the doctrine of substantial performance, giving that the change was minor and had no impact on the house's value or function. The homeowner's demand for perfection was considered unreasonable and unfair.
This case is important because it shows how the principle of substantial performance applies in contract law. It teaches us that if a contract is completed with good intentions and without serious problems, the party responsible can still be paid. Also, it demonstrates that courts won't strictly enforce contracts if it would lead to unfairness, and they will consider the parties' intentions and the effects of any deviations when deciding if a breach is significant.
The plaintiff built a home for the defendant, but the defendant noticed issues with the plumbing not meeting specifications. The plaintiff refused to redo the work and asked for final payment, which was declined, leading to legal action. The plaintiff argued that the installed brands were of the same quality, appearance, market value, and cost as the specified brand, but this evidence was excluded. The initial verdict was in favor of the defendant, but the Appellate Division granted a new trial. The courts recognize that not all omissions from a contract constitute a breach of condition, and that insignificant and innocent omissions may be atoned for by allowing resulting damages. The intention of the parties and considerations of justice are taken into account. The courts will not assume a purpose to punish minor faults with oppressive retribution, and will instead presume that the parties intended to account for reasonable and probable deviations from the contract. The lower court erred in excluding the evidence presented by the plaintiff.
The plaintiff breached their contract by using non-compliant pipe for plumbing in a building, which was discovered after completion. The plaintiff failed to provide evidence of the cost to fulfill the contract and did not act in good faith. The defendant had the right to contract for specific materials and was entitled to receive what the contract called for. The court affirmed the lower court's decision to direct a verdict for the defendant.
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