Britton v. Turner

Facts

The court said it could assume the following. Britton began work for Turner under a special contract to labor for Turner for one year for the sum of one hundred and twenty dollars. Britton labored nine and a half months. He then voluntarily stopped, with two and a half months of the term left, so he never finished the contract. Turner had the benefit of the labor Britton did. Britton sued for the reasonable value of that labor. The jury valued the labor Turner received. The court noted that if Turner's defence succeeded, Turner would keep nearly five sixths of the value of a whole year's labor because of the breach. Turner defended on the breach alone. The court said he did not appear to have offered evidence that the breach damaged him, or to have asked for any deduction for damage. The jury appeared to allow pay in proportion to the time Britton worked. One line of earlier decisions held that a worker who voluntarily fails to finish the whole labor recovers nothing for the part he did.

Issues

1. Can a laborer who voluntarily fails to finish a year's work under a special contract recover the reasonable value of the labor he actually performed, even though he cannot sue on the contract itself?
2. If he can recover, how is the employer's liability measured, and may the employer deduct the damage caused by the breach?

Holding

Britton could not sue on the contract, but he could recover the reasonable worth of his labor because Turner received a benefit from it. Turner did not appear to have offered proof of damage or to have asked for a deduction, so Britton was entitled to judgment on the verdict.