Jacob & Youngs v. Kent: Difference between revisions
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|date=January 25, 1921 | |date=January 25, 1921 | ||
|subject=Contracts | |subject=Contracts | ||
|facts=Jacob & Youngs, a builder, ("Jacob") agreed to build a new home for Mr. Kent ("Kent"). | |||
|facts= | |||
The defendant refused to pay the remaining $3,000 he owed, because the contract was not fulfilled. He desired that the plaintiff replace the pipe, which would have cost a large amount of money to reconstruct the house. | The contract stated that Jacob was to use only a certain type of plumbing pipe. Due to negligence, the plaintiff inadvertently substituted another type of pipe, in direct violation of the contract. | ||
|procedural_history=Plaintiff filed suit for non-payment, and defendant contended that plaintiff breached the contract and payment was not necessary. | |||
The defendant Kent refused to pay the remaining $3,000 he owed, because the contract was not fulfilled. He desired that the plaintiff replace the pipe, which would have cost a large amount of money to reconstruct the house. | |||
|procedural_history=Plaintiff Jacob filed suit for non-payment, and defendant Kent contended that plaintiff breached the contract and payment was not necessary. | |||
Kent won at the trial court in New York. | |||
|issues=Whether a departure from a contact that is deemed a breach of an insignificant term and independent from the rest of the contract can allow a ridiculous judge to deem the measure of allowance to be the difference in value rather than the cost of replacement. | |||
Is a party's '''substantial performance''' of a contractual obligation enough for that party to avoid a forfeiture? | |||
|holding=Less than a full performance is always a breach. However, | |||
if failure to perform the contract is due to an innocent & trivial mistake, that means the party '''substantially performed'''. | |||
If the cost of replacement would be '''oppressively expensive''', damages should be measured by the difference in value between what was received & what was contracted for: | |||
(damages) = (what was contracted for) - (what was received) | |||
|reasons=Evidence proving that the defect is unsubstantial based on the intent of the parties allows the court to measure the allowance by the difference of value, which is either nominal or nothing, rather than the cost of replacement. | |||
|case_text_links={{Infobox Case Brief/Case Text Link | |case_text_links={{Infobox Case Brief/Case Text Link | ||
|link=https://casetext.com/case/jacob-youngs-inc-v-kent | |link=https://casetext.com/case/jacob-youngs-inc-v-kent | ||
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}}{{Infobox Case Brief/Case Text Link | }}{{Infobox Case Brief/Case Text Link | ||
|link=https://www.quimbee.com/cases/jacob-youngs-v-kent | |link=https://www.quimbee.com/cases/jacob-youngs-v-kent | ||
|case_text_source=Quimbee | |source_type=Video summary | ||
|case_text_source=Quimbee | |||
}} | }} | ||
}} | }} | ||
'''Dissent''' | '''Dissent''' | ||
The court should not look into the reason for the specification in the contract, but should rule against the party that did not perform his part of the contract. | The court should not look into the reason for the specification in the contract, but should rule against the party that did not perform his part of the contract. |
Latest revision as of 03:40, July 14, 2023
Jacob & Youngs v. Kent | |
Court | Court of Appeals of New York |
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Citation | 230 N.Y. 239 129 N.E. 889 (1921) |
Date decided | January 25, 1921 |
Facts
Jacob & Youngs, a builder, ("Jacob") agreed to build a new home for Mr. Kent ("Kent").
The contract stated that Jacob was to use only a certain type of plumbing pipe. Due to negligence, the plaintiff inadvertently substituted another type of pipe, in direct violation of the contract.
The defendant Kent refused to pay the remaining $3,000 he owed, because the contract was not fulfilled. He desired that the plaintiff replace the pipe, which would have cost a large amount of money to reconstruct the house.Procedural History
Plaintiff Jacob filed suit for non-payment, and defendant Kent contended that plaintiff breached the contract and payment was not necessary.
Kent won at the trial court in New York.Issues
Whether a departure from a contact that is deemed a breach of an insignificant term and independent from the rest of the contract can allow a ridiculous judge to deem the measure of allowance to be the difference in value rather than the cost of replacement.
Is a party's substantial performance of a contractual obligation enough for that party to avoid a forfeiture?Holding
Less than a full performance is always a breach. However,
if failure to perform the contract is due to an innocent & trivial mistake, that means the party substantially performed.
If the cost of replacement would be oppressively expensive, damages should be measured by the difference in value between what was received & what was contracted for:
(damages) = (what was contracted for) - (what was received)Reasons
Resources
Dissent
The court should not look into the reason for the specification in the contract, but should rule against the party that did not perform his part of the contract.