Hawkins v. McGee Case Brief
The Hawkins v. McGee case brief is essential reading for every law student studying contract damages and is famously known as the "hairy hand" case. This landmark 1929 New Hampshire Supreme Court case established the modern approach to calculating expectation damages in contract law. Understanding the Hawkins v. McGee case brief helps students grasp how courts measure damages when a contract is breached, particularly the difference between expectation and reliance damages. This case appears in virtually every contracts casebook and is frequently tested on law school exams. The decision fundamentally shaped contract remedies by clarifying how to put the injured party in the position they would have been in had the contract been performed as promised.
Citation
Hawkins v. McGee, 84 N.H. 114, 146 A. 641 (1929)
Facts
George Hawkins, a young man, had a severe scar on the palm of his hand from a childhood accident. Dr. Edward McGee, a surgeon, promised to perform a skin graft operation that would restore Hawkins' hand to "one hundred percent perfect" condition. The doctor guaranteed that the operation would result in a "good hand" and that Hawkins would be able to do heavy work.
During the operation, Dr. McGee used skin from Hawkins' chest for the graft. However, the chest skin was hairy, and after the operation, thick hair grew on Hawkins' palm, making his hand worse than before the surgery. The hand became more unsightly and less functional than it had been with just the original scar. Hawkins sued for breach of contract, seeking damages for the failed surgery.
Issue
What is the proper measure of damages when a doctor breaches a contract to perform surgery by failing to achieve the promised result?
Rule
The proper measure of damages for breach of contract is expectation damages, which aim to put the injured party in the position they would have been in had the contract been performed as promised. Expectation damages are calculated as the difference between the value the plaintiff would have received if the contract had been performed and the value of what the plaintiff actually received.
Holding
The court held that Hawkins was entitled to expectation damages measured by the difference between the value of a "perfect hand" as promised and the value of the hand in its post-surgery condition.
Reasoning
The New Hampshire Supreme Court applied the expectation damages principle, focusing on the difference between what was promised and what was delivered. The court noted that Dr. McGee had made specific promises about the outcome of the surgery, creating a contract with measurable performance standards.
The court rejected the argument that damages should be limited to out-of-pocket expenses (reliance damages). Instead, it held that when a doctor makes specific promises about surgical outcomes, the patient is entitled to the benefit of the bargain. The proper measure was the difference between the value of a perfect hand (as promised) and the value of the hand in its actual post-surgery condition, which was worse than before the operation.
The court emphasized that the doctor's guarantee created a contractual obligation beyond the usual standard of reasonable care, making this a contract case rather than a malpractice case.
Significance
Hawkins v. McGee established the fundamental principle that expectation damages are the standard remedy for contract breach. This case demonstrates how to calculate damages by comparing the promised performance with the actual performance, even when the breach makes the plaintiff worse off than before the contract.
The decision is crucial for understanding contract remedies and appears in virtually every contracts course. It illustrates the difference between expectation damages (benefit of the bargain) and reliance damages (out-of-pocket costs), and shows how specific promises can create contractual obligations with measurable standards.
Why is Hawkins v. McGee important in law school?
Hawkins v. McGee is crucial in law school because it establishes the fundamental principle of expectation damages in contract law. This case appears in every contracts casebook and is frequently tested on exams. It teaches students how to calculate damages by comparing promised performance with actual performance, which is essential for analyzing contract remedies.
What legal rule came out of Hawkins v. McGee?
The case established that expectation damages are the proper remedy for contract breach. Expectation damages are calculated as the difference between the value of what was promised and the value of what was actually received. This puts the injured party in the position they would have been in had the contract been performed as promised.
How do professors use Hawkins v. McGee in class discussions?
Professors often use Hawkins v. McGee to explore different types of damages and remedies. They may ask students to calculate expectation versus reliance damages, or discuss when specific promises create contractual obligations. The case is also used to distinguish between contract and tort claims, and to introduce the concept of "benefit of the bargain" damages.
Why is this called the "hairy hand" case?
The case is nicknamed the "hairy hand" case because the surgery resulted in thick hair growing on the patient's palm after the doctor used hairy chest skin for the graft. This memorable detail makes the case easy to remember and illustrates how the breach actually made the plaintiff worse off than before the contract, which is important for understanding how expectation damages work.
Hawkins v. McGee remains one of the most important contract damages cases for law students to master. The expectation damages principle established in this decision continues to govern contract remedies today, making it essential knowledge for any lawyer. Understanding this case provides the foundation for analyzing contract damages and remedies throughout law school and legal practice.