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Peevyhouse v. Garland Coal & Mining Company

Melissa A. Hale

ProfessorMelissa A. Hale

CaseCast "What you need to know"

CaseCast –  "What you need to know"

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Peevyhouse v. Garland Coal & Mining Company
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    Brief Fact Summary. Plaintiffs leased their farmland to Defendant for strip mining on the condition that Defendant fill in the holes Defendant made after the completion of the mining. Defendant did not fill in the holes.

    Synopsis of Rule of Law. Damages for breach of contract cannot be so excessive that they cause economic waste

    Facts. Plaintiffs leased their farm to Defendant, a mining company for five years. Defendant performed strip mining. The contract included a provision where Defendant would do remedial work to fill in the holes caused by Defendant’s mining after the mining was complete. This work involved moving substantial amounts of dirt. Defendants did not do the remedial work. The trial court established that the remedial work would cost more than $29,000.00 and that the value of the farm would increase by $300.00. The court awarded Plaintiffs $5,000.00.

    Issue. Is Defendant liable for the costs of the remedial work?

    Held. No
    Case law, statute and Restatement of Contracts limit damages to those that do not cause economic waste or to those damages where the costs involved are not disproportional to the end obtained. Plaintiffs may not gain more in damages for a breach of contract that actual performance is worth.
    It is unlikely that a reasonable landowner would spend $29,000.00 to increase the value of a piece of land by $300.00.


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