n5 Instead, in each case the reasonableness referred to was that of
the efforts of the employee to obtain other employment that was not different or inferior;
his right to reject the latter was declared as an unqualified rule of law. Thus, Gonzales
v. Internat. Assn. of Machinists, supra, 213 Cal.App.2d 817, 823-824, holds that the trial
court correctly instructed the jury that plaintiff union member, a machinist, was required
to make "such efforts as the average [member of his union] desiring employment would
make at that particular time and place" (italics added); but, further, that the court
properly rejected defendant's offer of proof of the availability of other kinds of
employment at the same or higher pay than plaintiff usually received and all outside the
jurisdiction of his union, as plaintiff could not be required to accept different
employment or a nonunion job.
In Harris v. Nat. Union etc. Cooks, Stewards, supra, 116 Cal.App.2d
759, 761, the issues were stated to be, inter alia, whether comparable employment was open
to each plaintiff employee, and if so whether each plaintiff made a reasonable effort to
secure such employment. It was held that the trial court properly sustained an objection
to an offer to prove a custom of accepting a job in a lower rank when work in the higher
rank was not available, as "The duty of mitigation of damages . . . does not require
the plaintiff 'to seek or to accept other employment of a different or inferior
kind.'" (P. 764 [5].)
. . .
[citing a variety of cases, including Chisholm v. Preferred Bankers'
Life Assur. Co. (1897) 112 Mich. 50 [70 N.W. 415]]; each of which held that the
reasonableness of the employee's efforts, or his excuses for failure, to find other
similar employment was properly submitted to the jury as a question of fact. NB: Chisholm
additionally approved a jury instruction that a substitute offer of the employer to work
for a lesser compensation was not to be considered in mitigation, as the employee was not
required to accept it.
Williams v. National Organization, Masters, etc. (1956) 384 Pa. 413
[120 A.2d 896, 901 [13]]: "Even assuming that plaintiff . . . could have obtained
employment in ports other than . . . where he resided, legally he was not compelled to do
so in order to mitigate his damages."