Carolina Power & Light Company v. Paul

North Carolina is committed to the general rule that the measure of damages for injury to personal property is the differ ence between the market value of the damaged -property immediately before and immediately after the injury. The purpose of the rule is to pay the owner for his loss. If the damaged article has market value, the application of the before and after rule is relatively simple. Even in that case, however, the cost of repairs is some evidence of the extent of the damage. Simrel v. Meeler, 238 N.C. 668, 78 S.E. 2d 766. However, if there is no market, there can be no market value.…