Britton v. Turner
Superior Court of New Hampshire
6 N.H. 481 (1834)
Britton (plaintiff) agreed to work for Turner (defendant) for one year for $120, but quit after nine and a half months without Turner's consent; Turner refused to pay anything for the work already done, and Britton sued under a quantum meruit theory seeking payment for the value of his labor. At trial, Turner proved the breach but offered no evidence of any damages he suffered from it; the jury, instructed that Britton could recover under quantum meruit, awarded Britton $95, and Turner appealed the jury instructions.
Whether an employee who voluntarily breaches a labor contract by failing to complete the agreed term of employment is nonetheless entitled to payment for the reasonable value of the services actually provided.