Morris v. Sparrow
287 S.W.2d 583 (1956)
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Rule of Law:
A court of equity may grant specific performance for a contract involving a chattel if the chattel has a peculiar or unique value, and cashing a check for an undisputed monetary sum marked 'payment in full' does not constitute an accord and satisfaction that extinguishes a separate, disputed claim for non-monetary consideration.
Facts:
- Morris, a ranch owner, and Sparrow, a cowboy, agreed that Sparrow would work on Morris's ranch for 16 weeks for a monetary payment of $400.
- Sparrow alleged that as additional consideration for his work, he was also to receive a brown horse named Keno.
- Morris contended that the agreement to give Sparrow the horse was conditioned on Sparrow performing satisfactory work, which Morris claimed he did not do.
- During his employment, Sparrow used his expertise and spare time to train Keno from a 'practically unbroken' pony into what would become a 'first class roping horse'.
- After the 16-week period, Morris owed Sparrow a monetary balance of $167.
- At a bank, Morris gave Sparrow a check for the undisputed $167 balance with the notation 'labor paid in full'.
- Sparrow cashed the check but continued to assert his right to receive the horse.
Procedural Posture:
- Archie Sparrow sued Morris in the Arkansas Chancery Court (a court of equity acting as the trial court), seeking specific performance of the contract.
- The Chancellor found in favor of Sparrow and issued a decree ordering Morris to deliver the horse.
- Morris, as the appellant, appealed the Chancellor's decree to the Arkansas Supreme Court.
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Issue:
May a court grant specific performance for a contract to deliver a horse that has unique value to the buyer due to the buyer's own efforts in training it, and does cashing a check for an undisputed monetary amount marked 'labor paid in full' create an accord and satisfaction that bars a separate claim for the horse?
Opinions:
Majority - Sam Robinson
Yes, a court may grant specific performance for the horse, and no, cashing the check did not create an accord and satisfaction barring the claim. A court can compel the specific performance of a contract for a chattel where special reasons exist that make monetary damages inadequate. By training the unbroken pony into a roping horse, Sparrow gave the horse a peculiar and unique value, entitling him to the horse itself rather than its market value. Furthermore, the notation 'labor paid in full' on the check did not constitute an accord and satisfaction because there was no dispute between the parties as to the monetary amount owed. The check simply settled the undisputed cash portion of the labor agreement and did not extinguish the separate, disputed claim regarding the horse.
Analysis:
This decision reinforces the principle that specific performance is an appropriate remedy for chattels that are unique, not just by their nature, but also because of value added by the plaintiff's own efforts. It clarifies that a chattel's 'uniqueness' can be established by the personal skill and labor invested in it. The case also significantly narrows the application of the accord and satisfaction doctrine, holding that it cannot be used to extinguish a separate, disputed claim when a party accepts payment for a different, undisputed debt, even with 'payment in full' language.
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