McDonald v. John P. Scripps Newspaper
1989 Cal. App. LEXIS 338, 210 Cal. App. 3d 100, 257 Cal. Rptr. 473 (1989)
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Rule of Law:
To recover damages for a breach of contract, a plaintiff must prove a direct causal connection between the defendant's breach and the alleged injury. Damages that are purely speculative, remote, or contingent on a sequence of hypothetical events cannot serve as a legal basis for recovery.
Facts:
- Gavin L. McDonald was a contestant in the 1987 Ventura County Spelling Bee, sponsored by the Ventura County Star-Free Press and Scripps Howard.
- In a preliminary, school-wide competition, another contestant, Stephen Chen, was initially told he misspelled the word 'horsy,' but officials later discovered his spelling was a correct alternative.
- After the student who had been declared the winner of that school competition refused a rematch, officials decided to allow both him and Stephen Chen to advance to the county-wide bee.
- At the county-wide competition, Gavin McDonald competed against other students, including Stephen Chen.
- Gavin lost the spelling bee and came in second place after misspelling a word, while Stephen Chen was declared the winner.
Procedural Posture:
- Gavin L. McDonald, through a guardian ad litem, filed a lawsuit in a California trial court against the Ventura County Star-Free Press and the Scripps Howard National Spelling Bee.
- The complaint alleged causes of action for breach of contract, breach of the implied covenant of good faith and fair dealing, and infliction of emotional distress.
- The defendants filed a demurrer, arguing the complaint failed to state a valid cause of action.
- The trial court sustained the defendants' demurrer without leave to amend and dismissed the case.
- Gavin L. McDonald (appellant) appealed the dismissal to the California Court of Appeal.
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Issue:
Does a plaintiff state a valid cause of action for breach of contract when he cannot prove that the defendant's alleged breach of contest rules directly caused his loss, making his claimed damages purely speculative?
Opinions:
Majority - Gilbert, J.
No. A plaintiff fails to state a valid cause of action for breach of contract where the essential element of causation is missing. The complaint is fatally defective because Gavin cannot demonstrate that he was injured by the alleged breach of contest rules. He lost the spelling bee because he misspelled a word, a fact independent of whether Stephen Chen was properly allowed to compete. To prove damages, Gavin would have to show that 'but for' Stephen's presence, he would have won, which is impossible to establish and purely speculative. Any potential damages are remote and contingent, and courts do not provide relief for such claims. Furthermore, the decision of contest officials, much like that of a sports referee, does not typically present a justiciable controversy.
Analysis:
This case provides a clear and memorable illustration of the essential element of causation in contract law. The court's holding reinforces the principle that a defendant's breach must be the actual and proximate cause of the plaintiff's harm. The decision strongly discourages litigation based on speculative 'what if' scenarios, particularly in the context of competitions where outcomes are contingent on numerous variables. By classifying the dispute as a non-justiciable controversy, the court signals a broader judicial reluctance to intervene in the internal rulings and outcomes of private competitions and sporting events.
