August 21, 2009
On Paris, Zsa Zsa, 1988 and Alternative Measures of Damages
As summer wanes and 1L orientation draws to a close, it is part of the sweet rhythm of academia that a colleague inevitably says something like: "every year, they get younger." I'll admit, this year, I was the one who said it. And, in response, I was reminded that, of this incoming 1L class, there are some students who were born in 1988. 1988! (Apparently, at Northwestern, there's an incoming 1-L who may have been born in the 90's). (Image of Zsa Zsa, courtesy of Wikimedia Commons).
This has a lot to do with contracts, or at least the teaching of the subject.
In a previous post, I had asked if anyone happened upon a copy of the Goldberg v. Hilton decision. Ask on the glorious interwebs and ye shall receive. (Thanks, Eric Talley (Berkeley)).
Here's a copy of the decision: Download SLJQZ9-GoldbergvHilton. I think you'll agree that the facts provide a good example of the certainty limitation on damages, as well as the reliance v. restitution measure of damages. In the past, as an example on these points, I have used (and will continue to use) the Zsa Zsa Gabor case, Hollywood Fantasies. (The one where the celebrity fantasy vacation business bombs and the promoters blame it all on Zsa Zsa canceling her gig - purportedly because she had to film her 30 second cameo in Naked Gun 2 1/2). This year, I will try offering Goldberg v. Hilton as another example, given that involves an element of current (though similarly inexplicable) celebrity. My students born in 1988 might be interested.
Try it. If you just can't resist showing your relative age in pop-culture markers, you can mention that, for a time in the late 1940's, Zsa Zsa was married to Paris Hilton's great grandfather.
[Meredith R. Miller]
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