Lewis v. Holmes
61 L.R.A. 274, 34 So. 66, 109 La. 1030 (1903)
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Rule of Law:
Damages for non-pecuniary loss, such as mental anguish or humiliation, are recoverable for a breach of contract when the contract's object is the gratification of intellectual enjoyment, taste, or convenience, and such damages were reasonably within the contemplation of the parties at the time of contracting.
Facts:
- On April 6, Mrs. Anna Lewis contracted with D. H. Holmes for the creation of five dresses, to be delivered by April 17 for her daughter's wedding on April 19.
- Lewis informed Holmes that the dresses were for her daughter's wedding trousseau and were needed for social functions during her wedding tour.
- Holmes delivered the main wedding dress on April 16, but it was four inches too short in the front, causing the bride significant distress.
- Lewis immediately notified Holmes of the defect and provided the correct length for the remaining dresses.
- Holmes ceased work on the other four dresses, erroneously claiming Lewis had provided incorrect measurements and insufficient material, and never delivered them.
- As a result of not having the dresses, the bride had to forgo planned entertainments on her wedding tour and cut the tour short, causing her great chagrin and humiliation.
Procedural Posture:
- Mrs. Lewis, joined by her husband, sued D. H. Holmes in district court (trial court) for breach of contract.
- The district court found in favor of Lewis and awarded her $575 in damages.
- D. H. Holmes, the defendant, appealed the trial court's judgment to the Supreme Court of Louisiana.
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Issue:
Are damages for non-pecuniary harm, such as disappointment and humiliation, recoverable for a breach of contract to create and deliver a bridal trousseau in time for a wedding?
Opinions:
Majority - Provosty, J.
Yes. Damages for non-pecuniary harm are recoverable for a breach of contract to provide a wedding trousseau. The court reasoned that under Louisiana Civil Code article 1934, damages for breach of contract are not limited to pecuniary loss when the contract's object is the gratification of intellectual enjoyment or taste. A contract for a bride's trousseau falls squarely within this category. D. H. Holmes must be held to have contemplated that its failure to deliver the dresses would cause the bride keen disappointment and humiliation, as it knew the dresses were for her wedding and the subsequent festivities. The bride's resulting mortification from having to cancel social engagements and go to her husband without a suitable trousseau constitutes a direct harm for which damages are due.
Analysis:
This case is significant for affirming that damages for mental anguish can be recovered in contract law, an exception to the general rule limiting damages to pecuniary losses. It establishes that contracts of a personal nature, where the primary objective is emotional gratification or aesthetic satisfaction (like those for a wedding), fall under this exception. This precedent broadens the scope of recoverable damages for breaches of contracts related to significant life events, holding providers accountable not just for financial loss but also for the emotional distress their failure causes. Future cases involving breaches of similar personal service contracts would look to this decision to justify awards for non-economic damages.
