Roth v. Speck

Roth (plaintiff), a salon owner, hired Speck (defendant) as a hairdresser for one year, but Speck quit after six and a half months to take a better-paying job elsewhere, and Roth could not find a replacement without a loss. Roth sued for breach without offering expert testimony on a comparable hairdresser's market value, though he did present evidence of Speck's higher new salary; the trial court awarded Roth only nominal damages of $1.00, and Roth appealed.