## Facts

- Martha M. Carr, a New York resident, inherited unimproved 108-acre land in Richland County, South Carolina, in 1996.
- Raymond C. Campbell (and his family) had leased the property for roughly 30 years.
- In 1998, Carr asked Campbell’s wife about the property’s value; she communicated the county’s agricultural assessed value of about $54,000.
- On August 6, 1998, Carr and Campbell executed a written contract for Campbell to buy the property for $54,000; Campbell paid $1,000 in earnest money.
- Carr did not attend the closing, asserting the price was unfair; she returned the earnest money, which Campbell rejected and sent back to her.
- The county tax assessor’s fair market value for the property was about $103,700; Campbell admitted he had probably seen that figure and that only the lower agricultural value had been conveyed to Carr.
- Other valuation evidence placed likely sale value above the tax assessor’s figure, and an appraiser estimated fair market value at $162,000 as of the contract date.
- Carr had minimal familiarity with the land and had seen it only once as a child.
- Carr had been diagnosed with schizophrenia and depression (1986).
- In February 1999, Carr conveyed a one-half interest in the property to her cousin, Ruth Riley Glover.
- Campbell sued Carr and Glover seeking specific performance of the sale contract.

## Issues

1. Whether a court of equity should grant specific performance of a land-sale contract where the seller had schizophrenia and the contract price was far below fair market value.
2. Whether severe inadequacy of price, combined with the buyer’s superior knowledge and the seller’s mental illness, makes specific performance inequitable.

## Decision

- The South Carolina Court of Appeals reversed the master-in-equity’s decree ordering specific performance.
- The court held that compelling conveyance at the contract price was inequitable under the circumstances.
- The court treated the extreme price disparity, Campbell’s knowledge advantage, and Carr’s mental illness as collectively sufficient to deny equitable relief.

## Legal Principles

- Specific performance is discretionary equitable relief, not a remedy granted as a matter of right upon showing a valid contract.
- Inadequacy of consideration alone typically does not bar specific performance; however, extreme inadequacy combined with additional inequitable circumstances can justify denial.
- In deciding whether to grant specific performance, a court may consider relative knowledge and bargaining position, the fairness of enforcement, and the effect of a party’s mental condition on the equities.

## Conclusion

The appellate court denied specific performance because enforcing the $54,000 land-sale contract would be unjust in light of Carr’s schizophrenia, Campbell’s superior knowledge of the property’s higher value, and the large disparity between the contract price and fair market value.


Campbell v. Carr, 603 S.E.2d 625 (S.C. Ct. App. 2004)