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contractlawsuitdamagesequitywillspecific performance
contractdamagesequitytestimonywillspecific performance

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Morris v. Sparrow, 225 Ark. 1019, 287 S.W.2d 583

Facts

Morris, who owns a cattle ranch in Arkansas, and Sparrow, a cowboy from Florida, made an agreement during a rodeo that Sparrow would work at the ranch for 16 weeks for $400, with the additional promise of receiving a horse named Keno. While Morris contended that the horse was to be given only if Sparrow performed satisfactorily, Sparrow claimed he trained the horse during his time at the ranch. After the work period, Morris paid Sparrow the agreed amount but did not deliver the horse, leading to the lawsuit.

Morris owns a cattle ranch near Mountain View, Arkansas, and he also participates in rodeos. Sparrow is a cowboy, and is experienced in training horses; occasionally he takes part in rodeos. He lives in Florida; while at a rodeo in that state, he and Morris made an agreement that they would go to Morris' ranch in Arkansas and, later, the two would go to Canada. After arriving at the Morris ranch, they changed their plans and decided that, while Morris went to Canada, Sparrow would stay at the ranch and do the necessary work. The parties are in accord that Sparrow was to work 16 weeks for a money consideration of $400. But, Sparrow says that as an additional consideration he was to receive a brown horse called Keno, owned by Morris. However, Morris states that Sparrow was to get the horse only on condition that his work at the ranch was satisfactory, and that Sparrow failed to do a good job. Morris paid Sparrow the amount of money they agreed was due, but did not deliver the horse.

Issue

The main legal issue is whether Sparrow can enforce the agreement for the delivery of the horse through specific performance, despite Morris's claim that the agreement was conditional on satisfactory work.

First there is the issue of whether Sparrow can maintain, in equity, a suit to enforce, by specific performance, a contract for the delivery of personal property.

Rule

Equity will not ordinarily enforce a contract for the sale of chattels by specific performance unless special and peculiar reasons exist that make it impossible for the injured party to obtain relief through damages. Specific performance is authorized by Ark.Stats. § 68–1468.

Although it has been held that equity will not ordinarily enforce, by specific performance, a contract for the sale of chattels, it will do so where special and peculiar reasons exist which render it impossible for the injured party to obtain relief by way of damages in an action at law. McCallister v. Patton, 214 Ark. 293, 215 S.W.2d 701.

Analysis

The court found that the Chancellor had sufficient evidence to determine that the agreement for the horse was not conditional upon the quality of Sparrow's work. The court noted that the horse had unique value due to the training Sparrow provided, which could not be adequately compensated with monetary damages. The court also addressed the issue of accord and satisfaction, concluding that the notation on the check did not preclude Sparrow from claiming the horse, as there was no dispute over the amount owed.

Both parties were in Chancery Court and the Chancellor had a better opportunity than this court to evaluate the testimony of the witnesses; we cannot say the Chancellor's finding in favor of Sparrow is against the preponderance of the evidence.

Conclusion

The Supreme Court affirmed the Chancery Court's decree requiring Morris to deliver the horse to Sparrow, concluding that the evidence supported the finding that the agreement was not conditional.

Affirmed.

Who won?

Archie Sparrow prevailed in the case because the court found that the evidence supported his claim that the horse was promised as part of his compensation, and that the conditions set by Morris were not valid.

Morris claims that the part of the agreement whereby Sparrow was to receive the horse was conditional, depending on Sparrow doing a good job, and that he did not do such a job.

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