Browning v. Fies
4 Ala. App. 580, 1912 Ala. App. LEXIS 354, 58 So. 931 (1912)
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Rule of Law:
When a contract is breached, the non-breaching party may recover damages for mental anguish if the contract was made for a purpose related to matters of mental concern or solicitude, and the breaching party had knowledge of these special circumstances at the time of contracting.
Facts:
- The plaintiff contracted with the defendants, who operated a public livery business, to provide a carriage and team for a fee of $5.
- The plaintiff explicitly informed the defendants that the carriage was for the specific purpose of transporting him and his wedding party to his wedding ceremony at a church three miles away.
- The plaintiff specified that the carriage was needed at his home at 7:30 p.m. to get him to the church for his 8:00 p.m. wedding.
- The defendants accepted the payment and agreed to provide the carriage for this specified purpose at the agreed-upon time and place.
- The defendants failed to provide the carriage as promised and offered no excuse for their failure.
- As a result, the plaintiff and his wedding party, dressed in formal attire, were forced to take a public streetcar.
- They then had to walk several blocks from the streetcar line to the church.
- The wedding ceremony was delayed by 45 to 50 minutes, keeping the bride, minister, and guests waiting.
Procedural Posture:
- The plaintiff sued the defendants in the trial court for breach of contract, seeking both financial and non-economic damages.
- The defendants moved to strike the plaintiff's claims for damages related to mental anguish, humiliation, and distress.
- The trial court granted the defendants' motion, removing the claims for mental suffering from the case.
- The case proceeded to a jury trial limited to the issue of financial damages.
- The trial court instructed the jury that it could only award damages of $5.30 plus interest.
- The jury returned a verdict for the plaintiff in the amount of $6.55.
- The plaintiff (appellant) appealed the trial court's judgment and its ruling on the motion to strike to the Court of Appeals of Alabama.
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Issue:
Does a breach of a contract, entered into with knowledge of special circumstances where a breach would naturally and proximately cause mental anguish, allow the non-breaching party to recover damages for that mental suffering?
Opinions:
Majority - Pelham, J.
Yes, a breach of a contract entered into with knowledge of special circumstances allows for the recovery of damages for resulting mental suffering. When the special purpose of a contract is disclosed at the time of its formation, those special circumstances become incorporated into the agreement. Consequently, damages for a breach can include not only general financial loss but also special damages that were in the reasonable contemplation of both parties. Here, the defendants knew the contract was for the plaintiff's wedding—an event of a delicate nature where it is common knowledge that a failure of conveyance would cause distress, humiliation, and mental anguish. Analogizing to cases allowing mental anguish damages for the failure to deliver telegrams, the court holds that 'wounding a man's feelings' is a form of actual, recoverable damage when it is a proximate and foreseeable consequence of the breach under the known special circumstances.
Analysis:
This decision significantly broadens the scope of contract damages beyond purely pecuniary losses, particularly for contracts of a personal nature. It affirms that when the subject matter of a contract directly involves personal feelings and sensibilities, and this is known to both parties, foreseeable mental suffering is a compensable form of actual damage. This case solidifies the principle that contract law is not entirely detached from human emotion, creating a precedent for awarding non-economic damages in breaches of contract for services like weddings, funerals, or other highly personal events. It moves contract remedies closer to tort remedies in specific, foreseeable circumstances involving emotional harm.
