Liability for damages resulting from breach of contract
Groves
(p-lessor) v John Wunder (d-lessee)
205 Minn. 163 (1939)
Peevyhouse
(p-lessor)
v. Garland Coal (d-lessee) 382 P. 2d 109 (1963)
| Case 1 | Case 2 | ||
| Groves v. John Wunder |
Peevyhouse
v. Garland Coal |
||
| 1 | Type of property | Commercial | Farm |
| 2 | Situation at time of contract: | ||
| 3 | Expected benefit to promisor | Value of gravel | Value of coal |
| 4 | Expected cost to promisor | Lease payments + grading cost |
Lease payments + restoration cost |
| 5 | Situation at time of breach: | ||
| 6 | Specific performance | Grade land | Restore land |
| 7 | Cost of performance | $60,000 | $29,000 |
| 8 | Market value of performance | $12,000 | $300 |
| Two standards to consider in deciding what basis to use for awarding damages: | |
| (1) | "liability for damages has for its basis the value of the promised performance...when the breach occurred." (Groves v. John Wunder dissent) |
| (2) | "The only losses that can be said fairly to come within the terms of a contract are such as the parties must have had in mind when the contract was made" (Hawkins v. McGee) |
| Case outcomes table |
Case 1: Groves v. John Wunder |
|||
| Specific performance | Cost of performance | Market value of performance | ||
| Case 2: Peevyhouse v. Garland Coal |
Specific performance | |||
| Cost of performance | ||||
| Market value of performance | ||||