Sutton v. Temple

Brief Fact Summary.

Defendant and Plaintiff entered into an agreement in which Defendant was to lease Plaintiff’s land. The agreement did not state Defendant’s purpose of leasing the land. While on the land, Defendant’s cattle died due to the fact that the cattle ate the grass on the field that was poisoned. Defendant vacated the land and did not pay, as required by the lease agreement. Plaintiff brought suit to recover damages, and the jury held that Defendant was only liable for the time he spent on the land.

Synopsis of Rule of Law.

Despite the fact that the land is unfit for the tenant’s purpose, the tenant must pay rent for the land if the purposes of the land are not described in the lease and there is no implied warranty that the leased land will be fit for the tenant’s purpose.

Facts.

Thomas Temple (“Defendant”) contracted with Anne Sutton (“Plaintiff”) to lease Plaintiff’s field of edible grass for £40. Defendant wanted to lease the field to feed his cattle, but Defendant did not specify his intentions in the lease agreement. Further, Defendant did not know Plaintiff’s field’s grass was covered with manure that contained particles of paint. As a result of the lack of knowledge, many of Defendant’s cattle died after eating the grass. Subsequently, Defendant evacuated the land before to the lease’s termination date and refused to pay the £40, alleging the land was unsuitable for Defendant’s purpose. Plaintiff brought suit against Defendant to recover the £40. The jury determined that the cattle was poisoned by the paint, thus Defendant was only required to pay £12 for the time on the land. Defendant motioned, requesting the court to enter a verdict on his behalf. Plaintiff motioned to increase the damages to £26.

Issue.

Whether a tenant must pay rent for the land if the purposes of the land are not described in the lease and there is no implied warranty that the leased land will be fit for the tenant’s purpose, despite the fact that the land is unfit for the tenant’s purpose.

Held.

Yes, a tenant must pay rent for the land if the purposes of the land are not described in the lease and there is no implied warranty that the leased land will be fit for the tenant’s purpose, despite the fact that the land is unfit for the tenant’s purpose.

Concurrence.

Plaintiff is entitled fully recover from Defendant except if the lease agreement contained an implied warranty that the grass would be suitable for Defendant’s cattle to eat.This case does not contain any fraud allegations nor does it contain an express warranty that the grass would be suitable for the cattle to eat. The court properly did not find that an implied warranty existed in this case. Lastly, the court should overrule Smith v. Marrable, not follow its principles in this case. 

This case is not completely unlike Marrable. Nonetheless, there is some differences regarding the land, goods, and chattels.

The majority properly found that there is not an implied warranty in the lease agreement. Further, finding in that manner, would result in unforeseeable consequences. This case is unlikeMarrable, where the parities contracted for a furnished hotel. In that case, the parties to the contract understood that the house would be fit for immediate habitation. Also, the contract was more for the furniture than for the habitation. In this case, while Defendant will endure hardship because he has to pay the full contract price, the court cannot consider factors of hardship when creating a rule that has unforeseeable consequences.

Discussion.

Despite the fact that the land is unfit for the tenant’s purpose, the tenant must pay rent for the land if the purposes of the land are not described in the lease and there is no implied warranty that the leased land will be fit for the tenant’s purpose. The case at hand is unlike Smith v. Marrable, 152 Eng. Rep. 693 (Exch. 1843). In Smith, the parties contracted for a house and a furniture, and the court held that a house must be fit for immediate occupation when the contract specifically for both the house and the furniture. Thus, when one enters into a contract to provide a good or a house, the goods must be fit for its use, and the house must be habitable. Further, a renter may lease a house with faith that the house will be habitable and suitably furnished, exceptif the renter had a fair chance and opportunity to examine the house before to leasing it. Likewise, a good must be fit for its use; meaning one who provides a defected good is liable if the good is not fit for its use. Here, the contract between the parties for land. Additionally, the contract did not state the purpose Defendant intended to receive from leasing the land. Thus, Plaintiff’s right to recover from the lease is not conditioned on Defendant’s right to receive his intended benefit from the land, as there is no implied warranty that land will be suitable for Defendant’s purposes. Despite the fact that Defendant may face considerable hardship by being required to pay the full contract price, the court decides cases based on general principles of law, not on hardship. Therefore, Plaintiff is entitled to the full contract amount of £40.