Meador v. Toyota of Jefferson, Inc.
332 So.2d 433 (1976)
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Rule of Law:
Under Louisiana Civil Code Article 1934(3), non-pecuniary damages for breach of contract are not recoverable unless the gratification of intellectual enjoyment is a principal object of the contract. A contract for the repair of an automobile has as its principal object physical utility, not intellectual enjoyment, thus precluding recovery for damages such as aggravation and inconvenience.
Facts:
- Gretchen Meador, an eighteen-year-old, was the owner of a 1971 Toyota automobile.
- Following a collision, Meador brought her car to Toyota of Jefferson, Inc. for repairs in late February of 1972.
- Toyota of Jefferson, Inc. kept the vehicle for repairs for approximately seven months.
- During this period, Meador was deprived of the use of her car.
- The automobile was not returned to Meador until September 20, 1972.
Procedural Posture:
- Gretchen Meador and her father sued Toyota of Jefferson, Inc. in a Louisiana trial court for damages from the delay in repairing her vehicle.
- The trial court found for Meador and awarded her pecuniary damages as well as $700 in non-pecuniary damages for aggravation, distress, and inconvenience.
- Toyota of Jefferson, Inc. (as defendant-appellant) appealed to the Louisiana Fourth Circuit Court of Appeal.
- The Court of Appeal amended the judgment, reducing the pecuniary damages and disallowing the $700 award for non-pecuniary damages entirely.
- Meador (as plaintiff-applicant) sought and was granted a writ of certiorari by the Supreme Court of Louisiana to review the disallowance of the non-pecuniary damages.
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Issue:
Does a contract for the repair of an automobile have as a principal object the gratification of intellectual enjoyment or convenience under Louisiana Civil Code Article 1934(3), thereby allowing the owner to recover non-pecuniary damages for aggravation, distress, and inconvenience resulting from an unreasonable delay in the repair?
Opinions:
Majority - Calogero, J.
No. A contract to repair an automobile does not have intellectual enjoyment as a principal object, and therefore non-pecuniary damages for inconvenience and distress are not recoverable for its breach. The court reasoned by analyzing the original French text of Civil Code Article 1934(3), which showed that 'convenience' was intended as an example of 'intellectual enjoyment,' not as a separate basis for recovery. For non-pecuniary damages to be available, the gratification of intellectual enjoyment must be a principal, not merely incidental, object of the contract. The principal object of a car repair contract is physical gratification—the utility of having a working vehicle—so damages for aggravation and distress are not permitted.
Dissenting - Dixon, J.
Yes. A plaintiff should be able to recover damages for aggravation, distress and inconvenience when a repairman breaches a duty to fix a car within a reasonable time. The dissent argued that the distinction between tort and contract law is superficial and that justice requires compensation for damages that are reasonably foreseeable consequences of the breach, especially in a society highly dependent on automobiles. It pointed to tort cases where damages for inconvenience and mental anguish from property damage were allowed, arguing there is no logical reason to deny similar recovery in a contract case.
Concurring - Marcus, J.
No. Non-pecuniary damages are not recoverable here. In my view, damages for annoyance and emotional distress in breach of contract cases are only awardable when the gratification of purely intellectual enjoyment is the principal object of the contract, not merely a principal or concurrent object.
Analysis:
This case significantly narrows the scope for recovering non-pecuniary (emotional distress) damages in Louisiana breach of contract cases. By establishing the 'principal object' test and clarifying that 'convenience' is not an independent ground for recovery, the court created a higher bar for plaintiffs. The decision reinforces a stricter separation between contract remedies, which focus on economic loss, and tort remedies, which more readily allow for emotional harm. This ruling forces future courts to scrutinize the primary purpose of a contract to determine if it aims for intellectual gratification, like a contract for a wedding dress, versus physical utility, like a car repair.
