Quick Summary
Alice Sullivan (P) contracted a plastic surgeon to fix her nose to make it more aesthetically appealing and beautiful. Dr. O’Connor (d) conducted two surgical procedures on her as promised, but he could not make her nose seem better. Instead, the surgeries made her appearance worse. Sullivan filed a lawsuit for breach of contract and negligence. The trial court awarded reliance damages. Defendant appealed.
The damages fall under reliance damages, including pain, suffering, or mental distress, even if not foreseeable. Even though the plaintiff agreed to some suffering from the initial surgery, she experienced more for multiple surgeries and is entitled to damages.
Rule of Law
In the event of a breach of contract, the injured party may sue for damages that include direct and reasonable losses due to the breach.
Facts of the Case
A Professional singer Alice Sullivan (Plaintiff), hired plastic surgeon James O’Connor (Defendant) to fix her nose and make it more aesthetically appealing and beautiful. Dr. O’Connor conducted the two surgical procedures on her, but he could not make her nose seem better. Instead, the surgeries made her appearance worse. The first two procedures that O’Connor conducted on Sullivan were unsuccessful, so he performed a third surgery on her. However, this surgery did not fix Sullivan’s deformity, and subsequent surgeries could not enhance her look either.
Sullivan filed a lawsuit against O’Connor for breach of contract and negligence. While her negligence claim was unsuccessful, her breach of contract claim was upheld.
The trial awarded damages to Sullivan for breach of contract to cover her medical bills, her deformity, mental anguish connected to her career, and pain and suffering.
Damages granted by the jury were far more than Sullivan’s actual financial losses. As a result, O’Connor appealed to the Supreme Judicial Court of Massachusetts.
Issue
Did the trial court make a mistake when it considered anything but the plaintiff’s out-of-pocket expenses in calculating damages for breach of contract?
Holding and Conclusion
No.
The trial court decision was upheld. The damages fall under reliance damages, including pain, suffering, or mental distress, even if not foreseeable. Even though the plaintiff agreed to some suffering from the initial surgery, she experienced more for multiple surgeries. Plaintiff was not restricted to only real expenses, but she was also entitled to reliance damages.
Reasoning and Analysis
Plaintiff was entitled to compensation for her deteriorating health, pain, suffering, and emotional anguish that resulted from the third procedure—these things qualified for payment whether you look at it from either expectation or reliance damages.
Relevant FAQs of this case
How are reliance damages calculated?
Reliance damages are measured by what it would take to restore the injured party to their pre-contractual position. The damages are intended to put the injured party in the same position as if there had been no breach of contract.
More in-depth steps include:
- Determine whether the plaintiff relied on the defendant’s promise or not.
- Once there is evidence of reliance, then it is necessary to identify what it would have cost to avoid relying upon. This cost may be either direct expenditures or foregone opportunities.
- Once we know what it would have cost to avoid reliance, then we can calculate how much must be paid by the defendant in order to restore the plaintiff to status quo ante.
What is the goal of reliance damages?
The goal of reliance damages is to put the person who relied on the promise in the same position they would have been in if the promise had never been made.
Reliance damages serve as a punishment for bad faith. The purpose is not only to compensate the plaintiff for any losses incurred from a breach but also to deter future breaches by imposing an additional penalty on the breaching party.
References
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