Kirkland v. Archbold

Kirkland (plaintiff) contracted with Archbold (defendant) to repair Archbold's home for a total of $6,000, payable in installments tied to work milestones; after two months of work, Kirkland had been paid only $800 despite having rendered services reasonably valued at $2,895, and Archbold stopped him from continuing because Kirkland had not used the specified materials on the exterior walls. Kirkland sued for the difference between the $800 paid and the value of services rendered; the trial court treated the contract as severable, found Kirkland had earned and been conceded the first $800 payment, awarded him an additional $200, but denied further recovery on the theory that his subsequent breach (using wrong materials) entitled Archbold to stop the work and withhold further payment, and Kirkland appealed.