A painter agreed to paint a portrait for a client for $1,000. The contract specified that the painting must be 'to the client's complete satisfaction.' After the painter completed the portrait, the client genuinely expressed dissatisfaction with the work, claiming it did not capture her likeness adequately, even though objectively, several art critics praised the portrait's technical skill. The client refused to pay. Is the client obligated to pay the painter?
- ANo, because the contract made the client's 'complete satisfaction' an express condition precedent to payment.
- BYes, because the 'satisfaction' clause refers to a reasonable person's satisfaction, not the client's subjective whim.
- CNo, because contracts for personal services are generally unenforceable if satisfaction is subjective.
- DYes, because the painter completed the work with reasonable skill, and the client's dissatisfaction is unreasonable.
Show answer & explanationAnswer & explanation
Correct answer: A. No, because the contract made the client's 'complete satisfaction' an express condition precedent to payment.
When a contract involves personal taste or judgment (like a portrait), a 'satisfaction' clause is typically interpreted as requiring the subjective, honest satisfaction of the party to be satisfied. If the client genuinely (even if unreasonably from an objective standpoint) believes the work is unsatisfactory, the condition precedent to payment has not been met, and they are not obligated to pay. This is distinct from contracts involving mechanical fitness or utility, where an objective 'reasonable person' standard applies.
Why the other options are wrong
- B. The reasonable person standard applies to matters of mechanical utility, not personal aesthetic judgment.
- C. Contracts for personal services are generally enforceable, but the satisfaction clause here dictates the terms of payment.
- D. For contracts involving personal taste, objective reasonableness is not the standard.
Satisfaction Clause (Personal Taste)
A contract term making one party's performance contingent upon the other party's personal satisfaction. For matters of personal taste (e.g., art, custom clothing), subjective, honest dissatisfaction is sufficient to excuse performance.
- Applies where aesthetic judgment or personal preference is involved.
- Requires genuine, good-faith dissatisfaction, not merely feigned.
- Distinguished from clauses for mechanical utility, which use an objective 'reasonable person' standard.
Memory trick: Satisfaction's a feeling, not always a fact!