## Facts

- Becky J. Bond temporarily entrusted family photographs, birth records, and other family papers to Dottie Griffith, a reporter for A.H. Belo Corp., for use as background materials for a news story.
- The materials were lost while in the possession of Belo and Griffith.
- The parties stipulated that the items’ “actual value” was $2,500 and that their sentimental value to Bond was greater.
- Bond sought damages exceeding $2,500 based on the items’ sentimental value rather than their stipulated actual value.
- The trial court awarded Bond $2,500 and declined to award additional damages for sentimental value.

## Issues

1. Whether damages for loss of family photographs and personal papers may be based on sentimental value when the items’ market value is minimal.
2. Whether the trial court erred by limiting recovery to the stipulated “actual value” of $2,500 instead of allowing additional recovery based on sentimental or intrinsic value.

## Decision

- The court of appeals affirmed the trial court’s judgment.
- The court held that, on this record, Bond could not recover damages beyond the stipulated $2,500 based solely on sentimental value.
- The court concluded the trial court did not err in refusing to award an additional amount absent objective evidence supporting a non-speculative intrinsic (“value to the owner”) measure.

## Legal Principles

- The usual measure of damages for loss or destruction of personal property is its market value, or an agreed objective equivalent.
- When property has little or no market value, damages may be measured by its intrinsic or special value to the owner if supported by objective, non-speculative evidence (e.g., utility, replacement-related proof, or other concrete indicia).
- Purely sentimental or emotional attachment, standing alone, is generally not compensable because it is too speculative.
- A stipulation fixing “actual value” supplies an objective damages figure and, without additional proof justifying a different measure, supports limiting recovery to the stipulated amount.

## Conclusion

The court affirmed a $2,500 award for the loss of irreplaceable family papers and photographs, holding that a higher recovery could not rest on sentimental value alone and required objective proof of intrinsic value beyond the parties’ stipulated actual value.


Bond v. A.H. Belo Corp., 602 S.W.2d 105 (Tex. Civ. App. 1980)