In Howard v. Daly, 61 N.Y. 362 (1875), the Court determined that the defendant repudiated an employment contract with plaintiff actress before the term of employment commenced, by preventing the plaintiff from performing, and refusing to recognize the existence of the contract. The Court held, as a matter of law, that "the plaintiff should recover the whole amount of her stipulated compensation as the damages attributable to the defendant's breach of contract." Howard v. Daly, 61 N.Y. at 371.