A property developer who retains land purchased in reliance on a negligent misstatement of zoning, rather than selling it at a loss, does not necessarily fail to mitigate where the hope of rezoning is rationally based and the developer's business includes holding land for opportune development. A trial judge assessing damages for lost development opportunities may adopt a broad assessment approach rather than calculating precise profits from multiple hypothetical developments. The standard of mitigation required of a plaintiff is not high where the defendant is a wrongdoer.
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