Hansell v. Erickson
28 Ill. 257 (1862)
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Rule of Law:
An employee who enters into a contract to work for a specified period for a set sum and then voluntarily abandons the job without cause or the employer's consent before the term ends cannot recover any payment for the labor already performed.
Facts:
- A Plaintiff entered into a contract to work for a Defendant on his farm for a specific, entire period of time.
- The contract stipulated a certain sum to be paid for the entire term of labor.
- The Plaintiff was a Swedish immigrant who later claimed he did not understand the English language well.
- The Plaintiff quit his job before the end of the agreed-upon time, without the Defendant's consent and without a valid cause.
- The Plaintiff's departure occurred during the Defendant's busy harvest season.
Procedural Posture:
- The employee (Plaintiff) sued his employer (Defendant) in a trial court to recover wages for labor he had performed.
- A jury in the trial court found in favor of the Plaintiff.
- The trial court entered a judgment for the Plaintiff.
- The Defendant (employer) appealed the trial court's judgment to this appellate court.
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Issue:
Does an employee who voluntarily abandons their employment before the end of a specified contract term, without cause or the employer's consent, have a right to recover payment for the work performed prior to quitting?
Opinions:
Majority - Breese, J.
No, an employee who voluntarily quits a fixed-term contract without cause before its completion cannot recover for work already performed. The court held that a special contract for a fixed term is an entire contract that must govern the parties' obligations. When an employee breaches such a contract by abandoning their work, they forfeit the right to be paid on a quantum meruit basis (for the value of services rendered). The court dismissed the Plaintiff's claim of a language barrier as a 'flimsy pretext' and noted that leaving during the critical harvest season was 'contrary to justice and good morals.' It reasoned the contract is mutual; had the employer discharged the Plaintiff without cause, the Plaintiff could have recovered for the entire contract term. The court further clarified that a contract for 'six months at eight dollars per month' is an entire contract for the total sum, not a series of divisible monthly contracts.
Analysis:
This decision strongly affirms the 19th-century 'entire contract' doctrine, establishing a harsh 'all-or-nothing' rule for employees who breach fixed-term agreements. It reflects a judicial policy favoring employers and the strict enforcement of contracts to ensure stability, particularly in an agricultural economy dependent on seasonal labor. This 'willful breacher' rule has since been largely abandoned or modified in most jurisdictions, which now typically allow a breaching party to recover the value of the benefit they conferred, less any damages caused by the breach. Thus, the case serves as a historical benchmark for a more rigid and unforgiving era of contract law.
