Cameron v. Benson

Brief Fact Summary.

Cameron sued Benson for specific performance when Benson did not follow through with a contract for the sale of land.

Synopsis of Rule of Law.

Money damages are calculated using the time of specific-performance if the court awards money damages rather than specific-performance.

Facts.

Cameron contracted to buy land from Benson but Benson did not follow-through with the sale. Cameron sued Benson for specific performance when Benson did not follow through with a contract for the sale of land. The trial court granted Cameron specific performance of the contract as well as money damages. The appellate court increased the monetary damages and Cameron appealed.

Issue.

Whether money damages are calculated using the time of specific-performance if the court awards money damages rather than specific-performance?

Held.

Yes. The judgment of the appellate court is reversed and the trial court’s award is reinstated. Money damages should have been calculated from when the specific performance is awarded.

Discussion.

Money damages are calculated using the time of specific-performance if the court awards money damages rather than specific-performance. If a buyer of land seeks specific performance, money damages are based on when the court awarded specific performance, not when the breach occurred.