Redgrave v. Boston Symphony Orchestra, Inc.
United States Court of Appeals for the First Circuit
855 F.2d 888 (1988)
The Boston Symphony Orchestra (BSO, defendant) canceled its contract with actress Vanessa Redgrave (plaintiff) to narrate a performance after receiving public complaints about her political views; Redgrave sued for breach of contract, claiming the cancellation caused her to lose future professional opportunities, including three films she later joined (all eventually canceled for unrelated financial reasons) and a Broadway play whose producer, Theodore Mann, testified he decided against hiring her specifically because the BSO cancellation would have a negative effect if the production hired her. A jury awarded Redgrave $100,000 in consequential damages, but the district court granted judgment notwithstanding the verdict on First Amendment grounds despite finding the damages proven; Redgrave appealed.
Whether a plaintiff in a breach of contract action may recover consequential damages for the loss of identifiable professional opportunities caused by the breach.