Britton v. Turner
6 N.H. 481 (1834)
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Rule of Law:
Where a party provides beneficial service under a special contract for a specified term but voluntarily fails to complete the full term, they may recover in quantum meruit the reasonable value of the benefit conferred upon the other party, less any damages the other party sustained from the breach.
Facts:
- Britton entered into a special contract to work for Turner for a term of one year.
- The contract stipulated that Turner would pay Britton $120 for the full year of service.
- Britton commenced work under the contract.
- After laboring for approximately nine and a half months, Britton voluntarily abandoned the job.
- Britton did not complete the full one-year term of the contract.
- Turner received the benefit of the labor Britton performed for nine and a half months.
Procedural Posture:
- Britton (plaintiff) initiated an action against Turner (defendant) in a New Hampshire trial court to recover compensation for labor performed.
- The case was tried before a jury, which returned a verdict in favor of Britton.
- The jury found the value of the labor performed to be $95.
- Turner appealed the judgment on the verdict to the Supreme Court of Judicature of New Hampshire.
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Issue:
Does a party who voluntarily breaches a contract for a specific term of labor, after having partially performed, forfeit all right to payment for the labor they did perform?
Opinions:
Majority - Parker, J.
No. A party who fails to fully perform a contract for labor is not automatically precluded from recovering compensation for the services actually rendered. The traditional rule, which requires full performance as a condition precedent to payment, is unjust because it can subject a party who partially performs in good faith to a total loss, a penalty far greater than any actual damage suffered by the non-breaching party. The law should imply a new promise to pay for the reasonable value of the benefit that the employer actually received, especially since the employer, by the nature of a labor contract, accepts performance on a daily basis and cannot reject the benefit received. Recovery is based on the equitable principle of preventing unjust enrichment. The amount of recovery is the value of the benefit the employer received, which is calculated by taking the reasonable worth of the labor performed (not to exceed the contract rate) and subtracting the damages the employer sustained due to the employee's breach.
Analysis:
This case represents a significant departure from the harsh, traditional common law rule that required complete performance of an "entire contract" as a condition for any payment. By allowing a breaching party to recover in quantum meruit, the court shifted contract law towards a more equitable, restitution-based framework focused on preventing the unjust enrichment of the non-breaching party. This doctrine has been widely influential, particularly in employment and construction law, establishing the principle that a party should be compensated for the actual benefit they confer, even if they fail to meet all contractual obligations. It balances fairness to the breaching party against the non-breaching party's right to be compensated for damages.
