Pratt Furniture Company v. McBee
Supreme Court of New Hampshire
337 H.2d 119 (1987)
McBee (defendant) contracted to make 90,000 chairs for Pratt (plaintiff) at $10 each, but before allocating resources, received a far more lucrative order from Thompson Table Company for tables at $32 each, and his facility could only fulfill one order; McBee breached the Pratt contract to take the TTC deal, knowing he'd owe $90,000 in damages but still net $80,000 more profit overall. Pratt sued for an injunction and specific performance, or alternatively damages, restitution, and punitive damages; the trial court denied specific performance and punitive damages but awarded Pratt $90,000 in general damages, and Pratt appealed.
Whether the doctrine of efficient breach permits a contracting party to breach an agreement when performing would cause the party greater economic loss than breaching.