Chamberlain v. Parker 277 Mont. 198, 921 P.2d 1237 (Mont. 1996)
Chamberlain contracts with Parker to have a painting of himself painted. Parker doesn't finish the painting. The difference in value is $0, since the guy was ugly in the first place. Is there any liability for the painter for just walking away? Court ruled in this case that the painter must complete painting. In this case, the market doesn't reflect the value of the painting to the plaintiff. In the Jacob & Young vs. Kent case, the market value is the same as the value to the plaintiff. Market value is a reasonable standard in some cases, but it is not a reasonable standard in other cases.
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