Mistletoe Express Service v. Locke

Phyllis Locke (plaintiff) contracted with Mistletoe Express Service (Mistletoe) (defendant) to provide pickup and delivery services, spending money on vehicles, a ramp, dirt work, and other startup expenses (partly loan-financed); though she never turned a profit, her monthly losses shrank over time before Mistletoe canceled the contract, forcing her to close the business and sell the vehicles at a loss, while she still owed on her loan and had paid some interest. The jury awarded Locke $19,400 plus pre-judgment interest and $2,000 in attorney's fees, and Mistletoe appealed, arguing Locke could only recover unproven lost profits, not her expenditures.