Tuesday, December 3, 2013

Lloyd v. Murphy case brief

Lloyd v. Murphy case brief summary
153 P.2d 47 (1944)

Defendant appealed from a judgment of the Superior Court of Los Angeles County, California, which was entered for plaintiffs in a declaratory judgment action to determine whether defendant's obligations under his lease from plaintiffs had been terminated by war and to recover unpaid rent.

Plaintiffs leased property to defendant in 1941 to sell cars. In 1942, the government restricted car sales because of the war. Defendant repudiated his lease, and plaintiffs brought a declaratory judgment action to determine whether defendant's obligations under the lease were terminated by the government's restriction on car sales and, if not, to recover unpaid rent. The lower court found for plaintiffs.


  • On appeal, the court affirmed. 
  • The doctrine of frustration is limited to cases where the frustrating event was unforeseeable and the value of the bargained-for item is totally destroyed. 
  • In 1941, defendant was able to foresee the war and its consequences for car production. 
  • The value of defendant's lease was not wholly destroyed by the government restrictions because defendant was still permitted to sell some cars and could use the premises for other purposes. 
  • Thus, defendant was not entitled to relief from his lease.

The court affirmed the lower court's judgment because defendant was unable to establish that the doctrine of frustration relieved him of his obligations under the lease.

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