Restitution to the Party in Breach Flashcards
Britton v. Turner: rule of law
If an employee voluntarily breaches a contract for labor by failing to continue the agreed employment, the employee is entitled under quantum meruit to the reasonable value of the services provided, unless the contract specifically provides otherwise.
Britton v. Turner: facts
Britton (plaintiff) agreed to work for Turner (defendant) for one year for the sum of $120. After nine and a half months, Britton stopped working for Turner, without Turner’s consent. Upon Turner’s refusal to pay for the work completed, Britton sued Turner alleging, among other things, a claim for quantum meruit. On this basis, Britton claimed that he was entitled to $100 for the labor he had performed. At trial, Turner proved that Britton had agreed to work for one year and voluntarily failed to do so, but Turner presented no evidence of damages he incurred as a result of Britton’s breach. The trial court instructed the jury that Britton was entitled to recover under quantum meruit for the value of the labor that he performed, and the jury awarded Britton $95. Turner appealed the trial court’s instructions to the jury.
Britton v. Turner: issue
Is an employee who voluntarily breaches a contract for labor by failing to complete the agreed employment entitled to payment for the reasonable value of the services provided?
Britton v. Turner: holding
Yes. The rule that a contract for labor is entire and performance must be completed before payment is required prevents an employee who breaches from recovering under the contract. However, quantum meruit provides a basis outside the contract for the employee to recover the value of the services provided, unless the parties’ agreement stipulates otherwise. The rule applied to a contract for labor should be the same as that applied to a contract to furnish materials. In a contract to furnish materials, a failure to furnish all of the materials as promised prevents full payment under the contract. To the extent that the materials are accepted, however, an agreement is imputed that obligates payment for what was rendered in part performance of the contract. In contracts for labor, it can be presumed that the employer understands that performance can only be made incrementally, and therefore it is assumed, unless the parties specifically agree otherwise, that the performance is severable and the employee is entitled to payment for services rendered. If the rule that no payment is due until all performance has been completed was applied mechanically in these cases, the employer is likely to be overcompensated by the benefit of the employee’s labor, which may well exceed any minimal damages that arise from the employee’s breach. However, if an employee seeking to recover the value of his services under quantum meruit has caused damages to the employer which equal or exceed the value of the services he provided, then he may not recover and the employer can sue to recover damages exceeding the value of the services. Here, Turner introduced no evidence at trial of damages that he suffered due to Britton’s breach and the jury determined that the value of Britton’s services was $95. The trial court’s instructions to the jury were correct. The jury verdict is affirmed.
