The Superior Court of Pennsylvania, rejecting the common law rule, adopted Section 374 of the Second Restatement of Contracts, which would allow recovery by a defaulting purchaser of a business, who had also entered into a related lease for the property, of any part of his payments made prior to default.
Lancellotti v. Thomas, 341 Pa. Super. 1, 491 A.2d 117 (1985)
William G. Young,
Contracts - Defaulting Purchaser - Right to Restitution - Adoption of the Position Taken by the Second Restatement of Contracts in Pennsylvania,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol25/iss1/9