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Jones v. La Vallette was a case heard by the United States Supreme Court in 1866. The case involved a dispute between two parties over a contract for the sale of a steamboat. The plaintiff, Jones, had entered into a contract with the defendant, La Vallette, to purchase a steamboat for $2,000. Jones had paid $1,000 as a down payment and was to pay the remaining $1,000 upon delivery of the boat. La Vallette had failed to deliver the boat and Jones sued for breach of contract. The Supreme Court held that La Vallette was liable for breach of contract. The Court found that La Vallette had failed to fulfill his obligations under the contract and that Jones was entitled to damages for the breach. The Court also held that Jones was entitled to recover the $1,000 down payment, as well as any other damages he had suffered as a result of the breach. The Court's decision in Jones v. La Vallette established that a party who breaches a contract is liable for damages and that the non-breaching party is entitled to recover any money paid in advance. This case is still cited today as an example of the legal principles governing breach of contract.
In Jones v. La Vallette, the Supreme Court was tasked with deciding whether a contract between two parties could be enforced if it had been made without consideration and in violation of a state statute. The majority opinion held that such contracts were not enforceable because they violated public policy as expressed by the state legislature. Justice Field dissented from this decision, arguing that while he agreed with the majority's conclusion on its face, there should have been an exception for cases where both parties to the contract acted in good faith and relied upon each other’s promises when entering into their agreement. He argued that enforcing these types of contracts would promote justice rather than violate public policy since it would prevent one party from taking advantage of another who had acted honestly and reasonably under all circumstances. Furthermore, Field reasoned that allowing courts to refuse enforcement based solely on lack of consideration or statutory violations could lead to injustice due to unforeseen consequences or technicalities which may arise after-the-fact but were not present at time of formation.