Moorman v. Levitch

26 Ohio N.P. (n.s.) 540
CourtCourt of Common Pleas of Ohio, Hamilton County
DecidedOctober 15, 1927
StatusPublished
Cited by1 cases

This text of 26 Ohio N.P. (n.s.) 540 (Moorman v. Levitch) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Hamilton County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Moorman v. Levitch, 26 Ohio N.P. (n.s.) 540 (Ohio Super. Ct. 1927).

Opinion

Darby, J.

This is an action in which the plaintiff seeks to recover damages from the defendant for the failure of the defendant to complete the contract by which the plaintiff agreed to sell and the defendant to buy certain real estate.

The defendant moves to strike from the petition, allegations of a resale of the property after defendant’s refusal to fulfill the contract. The contract price was $18,000, $200 of which was paid on the signing of the contract. The petition alleges that the plaintiff sold the property to another, after defendant’s breach, for $15,809.74. The de[541]*541feridant seeks to strike out the allegation pertaining to the resale of the property above mentioned.

The correct determination of the motion depends to a large extent upon the true measure of damages of plaintiff for the alleged breach of contract.

The position of the plaintiff is that he is entitled to recover as part of his damages, the difference between the contract price and the resale price of the property.

On the other hand, the defendant’s claim is that the true measure of damages is the difference between the contract price and the market or sale value of the property at the time of the alleged breach.

In McCarthy v. Lingham, 111 O. S., 551, the Supreme Court had before it the question as to the proper measure of damages of a vendee upon breach of contract for sale of real property. In syllabus 3, the court states the rule as follows:

“3. The measure of damages in such case is the difference between the market value of the property at the time the conveyance should have been made, and the sale price stated in the contract.”

Is there any reason for any different rule in case the action is by the vendor for the breach by the vendee?

In Eisenstadt et al v. Lucke et al, 25 C. C. (N.S.), 225, in an action against the vendee for refusal to complete the contract the Court of Appeals of Hamilton county stated the rule as follows:

“2. The measure of damages in such a case is the difference between the contract price and the market price, at the time of the breach, and it is error to admit evidence as to what the property brought when offered at public auction at a later date, and upon different terms.”

In the case at bar there is no claim of a public auction.

While there is not entire unanimity of opinion throughout the United States concerning the true measure of damages in such case, by far the greater weight of authority is that the true measure of damages is the difference be-[542]*542between the contract price and the market value of the land at the time of breach.

In Cowdery v. Greenlee, 126 Ga., 786, syllabus 3 is as follows:

“The refusal of the purchaser to perform will not give to the owner the right to resell the land at the risk of the former, and hold him liable for deficiency in the price realized, the true measure of damages being the difference between the contract price and the market value of the land at the time of the breach.”

In Pritchard v. Mullhall, 127 Ia., 545, the rule is stated in these words:

“A vendor’s damages for breach of a contract, where he retains the title to the land is the difference between the contract price of the land and its market value at the time of the breach, less any portion of the purchase price already paid.”

In Allen v. Mohn, 86 Mich., 328, the rule is given in these words:

“2. The measure of damages in a suit by the vendor in a land contract for its breach, is the difference between •the contract price and the value of the land at the time of re-entry, less the payments made thereon.”

In Griswold v. Sabin, 51 N. H., 167, it is said:

“In contracts for the purchase and sale of real estate where the vendee refuses to receive the deed and pay for the land, the measure of damages which the vendor may recover in a suit at law is the difference between the price agreed to be paid for the land and its real value at the time the contract was broken.”

In Harmon v. Thompson, 119 Ky., 528, syllabus 7 is as follows:

“The measure of damages for breach of a contract to buy land as between the vendor and the vendee, is the difference between the contract price and the actual value of the land on the date of the breach, when the actual value is less than the contract price, in addition to which interest may be awarded.”

[543]*543In Porter v. Travis, 40 Ind., 556, the syllabus is as follows:

“While a vendor may,, by an action for specific performance of a contract against the vendee, compel the acceptance of the conveyance of the land sold and the payment of the purchase money, yet when the suit is for damages against the vendee for a breach of the contract in refusing to accept the deed and pay the purchase money, the measure of damages is the difference between the contract price and the value of the land at the time when the deed should have been accepted, if at that time there was any decrease in such value.”

In Wilson v. Hoy, 120 Minn., 451, the court say:

“The measure of damages in such a case is the difference between the contract price and the actual or market value of the land at the time of the breach, and not the difference between the contract price and the cost of the property to the vendor.”

In Old Colony R. R. Corp. v. Evans, 6 Gray, 25, it is said:

“In an action at law by the vendor to recover damages for the breach of a contract for the sale of land, the measure of damages is not the full contract price, but the difference between that price and the price for which the land could have been sold at the time of the breach.”

In Maryland Clay Co. v. Simpers et al, 96 Md., 1, the court say:

“In an action for breach of a contract to buy land, the measure of damages is the difference between the actual value of the land sold, and the price defendant agreed to pay.”

In Sloan v. Baird, 162 N. Y., 327, the court say:

“In an action to recover unliquidated damages for the breach of an executory contract to convey property, interest is not allowable unless there is an established market value of the property, or means accessible to the party sought to be charged, of ascertaining by computation or otherwise, the amount to which the plaintiff is entitled,”

[544]*544See also 2 Sutherland on Damages, 4 ed., Sec. 570; 3 Sedgewick on Damages, 9 ed., Sec. 1023.

Many other cases might be multiplied upon this point, but sufficient has.been given to show the general and prevailing rule upon the subject.

In Eisenstadt v. Lucke, infra, on p. 227 the court say:

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26 Ohio N.P. (n.s.) 540, Counsel Stack Legal Research, https://law.counselstack.com/opinion/moorman-v-levitch-ohctcomplhamilt-1927.