Britton v. Turner: Difference between revisions

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{{Infobox Case Brief}}
{{Infobox Case Brief
''Britton v. Turner'', 6 N.H. 481 (1834).
|court=New Hampshire Supreme Court
|citation=6 N.H. 481 (1834)
|date=July 1, 1834
|subject=Contracts
|appealed_from=Court of Common Pleas (New Hampshire)
|facts=Plaintiff (Mr. Britton) was hired to work for the defendant (Mr. Turner) for 1 year, and at the end of that year, he would receive his yearly wages of $120 ([https://www.wolframalpha.com/input?i=US%24120+%281834+US+dollars%29 roughly $44,000 in 2023]) from March 1831 to March 1832.  


'''Facts''': Plaintiff was hired to work for the defendant for one year, and at the end of that year, he would receive his yearly wages of $120. After about 9 1/2 months, Plaintiff left the employment. Defendant refused to pay Plaintiff for the work that Plaintiff completed in the 9 1/2 months.
After about 9 1/2 months, Britton left the employment in December 1831. Turner refused to pay Britton for the work that Britton completed in the 9 1/2 months.
|procedural_history=Britton sued Turner for $100.


Jury was instructed that Plaintiff (Britton) should receive the value of the labor that he performed.


'''Proc. Hist''': Jury was instructed that Plaintiff should receive the value of the labor that he performed. Jury returned verdict of $95. Defendant appealed, excepting to the jury instructions.
Jury returned verdict of $95. Defendant appealed, excepting to the jury instructions.
|issues=Should Defendant (Turner) owe any money to Plaintiff (Britton) when Britton voluntarily left the contractual employment?
|holding=Plaintiff (Britton) should receive the amount commensurate to the work performed.


Britton can't recover damages, but he can recover in ''[[Contracts/Quantum meruit|quantum meruit]]'' for the value of his services.
|judgment=Affirmed.
|reasons=If Defendant (Turner) did not have to pay anything to Plaintiff (Britton), then other employers would have motivation to try to drive their employees away after substantial work is finished but before it is completed.


'''Issue''': Should Defendant owe any money to Plaintiff when Plaintiff voluntarily left the contractual employment?
Also, employees would have incentive to quit without starting because they would know that any work completed, short of fully performing the contract, would go uncompensated.
 
|rule=The implied promise is to pay such amount of the stipulated price for the whole labor, as remains after deducting what it would cost to procure a completion of the residue of the service, and also any damage which has been sustained by reason of the non-fulfillment of the contract.
 
|case_text_links={{Infobox Case Brief/Case Text Link
'''Holding''': Plaintiff should receive the amount commensurate to the work performed.
|link=https://www.quimbee.com/cases/britton-v-turner
 
|source_type=Video summary
 
|case_text_source=Quimbee
'''Reasons''': If Defendant did not have to pay anything to Plaintiff, then other employers would have motivation to try to drive their employees away after substantial work is finished but before it is completed. Also, employees would have incentive to quit without starting because they would know that any work completed, short of fully performing the contract, would go uncompensated.
}}{{Infobox Case Brief/Case Text Link
 
|link=https://www.lsd.law/briefs/view/britton-v-turner-39016782
 
|source_type=Case brief
'''Judgment''': Affirmed.
|case_text_source=LSD
 
}}
 
}}
'''Rule''': The implied promise is to pay suchamount of the stipulated price for the whole labor, as remains after deductingwhat it would cost to procure a completion of the residue of the service, andalso any damage which has been sustained by reason of the <span class="SpellE">nonfulfillment</span>of the contract.
{| class="wikitable"
 
|+
 
! colspan="5" |Contract litigation
[[Category:Cases:Contracts]]
|-
| colspan="2" |Breach of contract
| colspan="3" |Quantum meruit
|-
|
|
| rowspan="2" |Implied contract
| rowspan="2" |Quasi-contract
| rowspan="2" |Unjust enrichment
|-
|
|
|}

Latest revision as of 19:34, July 14, 2023

Britton v. Turner
Court New Hampshire Supreme Court
Citation 6 N.H. 481 (1834)
Date decided July 1, 1834
Appealed from Court of Common Pleas (New Hampshire)

Facts

Plaintiff (Mr. Britton) was hired to work for the defendant (Mr. Turner) for 1 year, and at the end of that year, he would receive his yearly wages of $120 (roughly $44,000 in 2023) from March 1831 to March 1832.

After about 9 1/2 months, Britton left the employment in December 1831. Turner refused to pay Britton for the work that Britton completed in the 9 1/2 months.

Procedural History

Britton sued Turner for $100.

Jury was instructed that Plaintiff (Britton) should receive the value of the labor that he performed.

Jury returned verdict of $95. Defendant appealed, excepting to the jury instructions.

Issues

Should Defendant (Turner) owe any money to Plaintiff (Britton) when Britton voluntarily left the contractual employment?

Holding

Plaintiff (Britton) should receive the amount commensurate to the work performed.

Britton can't recover damages, but he can recover in quantum meruit for the value of his services.

Judgment

Affirmed.

Reasons

If Defendant (Turner) did not have to pay anything to Plaintiff (Britton), then other employers would have motivation to try to drive their employees away after substantial work is finished but before it is completed.

Also, employees would have incentive to quit without starting because they would know that any work completed, short of fully performing the contract, would go uncompensated.

Rule

The implied promise is to pay such amount of the stipulated price for the whole labor, as remains after deducting what it would cost to procure a completion of the residue of the service, and also any damage which has been sustained by reason of the non-fulfillment of the contract.

Resources

Contract litigation
Breach of contract Quantum meruit
Implied contract Quasi-contract Unjust enrichment
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