Peevyhouse v. Garland Coal and Mining Co.

Facts: Defendant contracted with Plaintiff to use Plaintiff's land as a coal mine, and after such use to clean up the area, which was estimated to have cost Defendant $29,000 to conduct. Defendant didn't clean up.

Procedural History: Plaintiff sued for $25,000 damages for breach of contract. Jury awarded $5,000 to Plaintiff (more than the value of the entire farm, even after the clean up is done).

Issue: What amount of damages is owed to Plaintiff? Expected damages would be the amount to clean up ($29,000) and reliance damages would be the loss of value to the farm (estimated at a couple hundred dollars).

Holding: Damages are limited to diminution of value resulting from the non-performance.

Reasons: If the work to be done is "disproportionate to the end to be attained" the value rule should be followed. The provision that was breached was merely incidental to the main provisions of the contract.

Judgment: Award for damages should be reduced to $300.