Case brief summary
When someone breaks a promise in a contract to fix up land, and that promise was just a small part of the deal, courts can limit the money owed to how much the land's value actually dropped, instead of the full cost of doing the repair work, if that cost is way out of proportion to the benefit gained.
Facts
A couple let a coal company strip mine their farm, and the company promised to restore the land afterward. It kept every other promise but never did the restoration work, even though it was able to.
Procedural history
The landowners sued for breaking the promise. A jury awarded them 5000 dollars, less than they wanted. Both sides appealed, the landowners wanting more and the company wanting less.
Issue
When fixing broken land would cost far more than the value it adds, should payment be based on the repair cost or on the actual drop in land value?
Holding
The court ruled that payment should match the actual drop in land value, only 300 dollars, instead of the much higher cost of doing the repair work.
Reasoning
The restoration promise was a small part of a coal mining deal, not a building contract. Since fixing it would cost 29000 dollars but only add 300 dollars in value, paying full cost would unfairly overpay the landowners.
Opinions
Majority (Jackson): Damages for breach of an incidental restoration promise are limited to the drop in land value when the repair cost is grossly disproportionate to that value.
Dissent (Irwin): The company willfully broke its promise and should have to pay the full cost of performing the restoration work it agreed to do.