Britton v. Turner

6 N.H. 481 (1834)

Quick Summary

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In ‘Britton v. Turner’, Britton (plaintiff) sued Turner (defendant) for compensation after leaving his year-long employment early. The dispute centered around whether Britton deserved payment for his nine and a half months of labor despite not fulfilling his contract’s full term.

The New Hampshire Supreme Court of Judicature decided that Britton was entitled to payment under quantum meruit since he provided beneficial services to Turner. The court ruled this way to ensure fairness and prevent undue advantage from technical breaches of contracts.

Facts of the Case

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Britton (plaintiff) entered into an agreement to work for Turner (defendant) for a one-year period in exchange for $120. However, Britton ceased working after nine and a half months, leaving without Turner’s consent. When Turner refused to pay for the work that had been done, Britton sued Turner, asserting a claim for quantum meruit, which is a legal principle allowing a person to recover the value of work performed. Britton claimed he deserved $100 for the labor he had provided.

Turner, on the other hand, presented evidence at trial that Britton had agreed to work for one year and failed to do so voluntarily, yet Turner did not provide evidence of any specific damages resulting from Britton’s early departure. The trial court instructed the jury that Britton was entitled to compensation for the value of his labor under quantum meruit, and the jury awarded Britton $95.

Procedural Posture and History

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  1. Britton sued Turner for payment for labor performed under an agreement.
  2. The trial court found in favor of Britton, awarding him $95.
  3. Turner appealed the trial court’s decision and instructions to the jury.

I.R.A.C. Format


Issue Icon

Whether Britton is entitled to recover payment under quantum meruit for labor performed, despite not completing the full term of the contract he had agreed to with Turner.

Rule of Law

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A party who undertakes work under a special contract is not liable under that contract until the work is completed according to its terms. However, if a party receives useful labor or materials that result in a benefit beyond any damages caused by breach of contract, the law implies a promise to pay for the reasonable worth of that benefit.

Reasoning and Analysis

Reasoning Icon

The court acknowledged the complexity of cases involving partial performance of contracts. It compared the situation to other scenarios, such as construction contracts where work is accepted despite variations from the original agreement or sales contracts where only part of the goods are delivered but still used by the buyer.

The court reasoned that if an employer benefits from labor, even if the contract isn’t fully performed, they should pay for the value of that labor. It also highlighted that by allowing recovery for partial performance, it prevents employers from exploiting technical breaches and encourages fair dealings between parties.

Moreover, the court emphasized that damages should be considered when determining payment for partial performance. If damages equal or exceed the value of labor performed, then no payment would be due. The court’s analysis sought to balance fairness and practicality, ensuring that workers are compensated for their contribution while holding them accountable for unfulfilled agreements.


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The court affirmed the trial court’s decision, concluding that Britton was entitled to recover under quantum meruit for his labor’s reasonable worth as he had provided beneficial service to Turner.

Key Takeaways

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  1. If a worker fails to complete a contract but provides useful labor, they may be entitled to payment for the reasonable worth of their labor.
  2. An employer can deduct damages resulting from a breach of contract from any payment owed for partial performance.
  3. The ruling seeks to balance fairness between parties, ensuring workers are compensated while holding them responsible for incomplete agreements.

Relevant FAQs of this case

What legal principles justify compensation for partial performance of a contract?

Quantum meruit legal principle justifies compensation for partial performance by allowing recovery of the reasonable value of services rendered, despite non-completion of contractual terms.

  • For example: A graphic designer contracted to create a full branding package for a company but only completes the logo design before the contract is terminated. The designer may still be entitled to compensation for the value of the logo design.

Under what conditions can damages from breach of contract be deducted from compensation for partial performance?

If partial performance has caused damages to the non-breaching party, those damages can be deducted from any owed compensation, provided they directly result from and are proportionate to the breach.

  • For example: An event planner partially organizes a conference but quits, causing the hiring entity to incur additional costs to complete the planning. These costs can be deducted from the payment owed for the planner’s partial services.

How does contract law ensure fair treatment of both parties in cases of partial performance?

The doctrine of quantum meruit ensures that parties receive fair treatment by compensating for services rendered while allowing deductions for any losses due to non-fulfillment of contract terms.

  • For example: A freelancer writes six out of ten promised articles before a contractual dispute halts work. Payment is given for the six articles, but if the incomplete work resulted in lost revenue for the client, this may offset the payment.
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