This depends on the value of repeat business. Here that value is really really small, both with this customer and potentially similar customers who might or mig

This depends on the value of repeat business. Here that value is really really small, both with this customer and potentially similar customers who might or might not hear about the incident. Also the web designer is a small player in a big pond, reducing further the risk to his reputation. The customer - before the retaliation - believed the risk of non-payment to be worth it. Often in small contract work, the contractor can't profitably sue or they believe it's not worth the harassment. Unless the customer can now sue the web designer for additional damages, this might be strategically the best thing he could do.