On appeal, the New Hampshire Supreme Court held that the amount of damages awarded should be equal to the difference between the value of what Hawkins was promised to receive—a "one hundred percent good hand" — and what he in fact received—a hairy palm—as well as any incidental losses he incurred as a result of the breach. This is known as expectation interest (or expectation damages), which attempts to put the plaintiff into a position where they would have been had the contract not been breached. The court made a point of dismissing the argument on damages for the pain and suffering because pain and suffering were an implicit part of the contract for surgery.