Britton v. Turner

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Brief Fact Summary. The Plaintiff sued the Defendant to recover money allegedly owed to him under a labor contract.

Synopsis of Rule of Law. Where a party to a contract cannot derive a benefit from the other party’s part performance of the contract, the other party cannot recover in quantum meruit for services rendered. However, where the other party has conferred a benefit upon the party, even though he does not complete performance, he may still recover in quantum meruit.

Points of Law - Legal Principles in this Case for Law Students.

In this state it is settled that when a party is sued upon a contract which has been broken, if he elects to have his damages considered in the action against him, he must be understood as conceding that they are not to be extended beyond the amount of what he has received, and he cannot afterwards sustain an action for further damages.

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Facts. The Plaintiff agreed to work for the Defendant for one year for a sum of $120. While the Plaintiff worked for the Defendant, he performed the labor required of him under the contract. Before the expiration of the one-year term, the Plaintiff left the Defendant’s service without his consent. There was no evidence that the Plaintiff’s departure caused any damage to the Defendant except the nonfulfillment of the contract. The Plaintiff thereafter sued in quantum meruit to recover for the labor already performed.

Issue. Can the Plaintiff recover a reasonable sum for the service he has actually performed on a contract that he did not fully perform?

Held. Yes. Where a party to a contract cannot derive a benefit from the other party’s part performance of the contract, the other party cannot recover in quantum meruit for services rendered. However, where the other party has conferred a benefit upon the party even though he does not complete performance, he may still recover in quantum meruit. Here, the Defendant did not offer evidence to show that he was damaged by incomplete performance. Therefore, the Plaintiff was entitled to recover for the reasonable value of his services rendered.

Discussion. A person who does not complete performance on a contract may still receive money for services rendered before the breach.

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