Midland Mutual Life Insurance Co. v. Mercy Clinics, Inc.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting that the majority of jurisdictions have concluded that the collateral source rule should not be applied outside the realm of tort actions
• declining to apply collateral source rule in pure contract action involving borrower’s alleged breach of estoppel agreement with lender
• noting the measure of damages for a breach of contract should place the non-breaching party “in as good a position as [they] would have occupied had the contract been performed”
• leaving open application of rule in cases of tortious or willful breach
• “Typically, the nonbreaching party’s recovery is limited to ‘the loss he has actually suffered by reason of the breach.’” (citation omitted)
• cited with approval in Shelby County Cookers, LLC v. Utility Consultants International, Inc., 857 N.W.2d 186, 195 (Iowa 2014)

Source: CourtListener parenthetical corpus (CC0).