Wednesday, December 25, 2013

Betaco, Inc. v. Cessna Aircraft, Co. case brief

Betaco, Inc. v. Cessna Aircraft, Co. case brief summary
32 F.3d 1126 (1994)

Appellant seller sought review of the judgment of the United States District Court for the Southern District of Indiana, which rejected appellant's contention that the purchase agreement signed by the parties was a fully integrated document that precluded appellee purchaser's attempt to rely on the warranty.

Appellee purchaser agreed to buy a jet from appellant seller based in part on appellant's representation in a cover letter accompanying the purchase agreement that the new jet was faster and more efficient than another popular model. After giving appellant a deposit, appellee decided to cancel the purchase. When appellant refused to return appellee's deposit, appellee filed a suit claiming that appellant breached an express warranty.


  • The court reversed the district court's entry of partial summary judgment in favor of appellee on the threshold integration issue, concluding that a question of fact existed as to the parties' intent. 
  • The court held that while the parties agreed that they intended the signed purchase contract to be a final expression of the terms set forth within the four corners of the contract, appellee relied on the cover letter as evidence of a consistent additional term of the agreement and Kan. Stat. Ann. § 84-2-202 barred that evidence. 
  • Therefore, the court remanded for a hearing in which the district judge would sit as a finder of fact and decide whether the parties intended the purchase agreement to be the complete embodiment of their understanding.

The court reversed the entry of partial summary judgment against appellant seller, holding that the record before the district court on summary judgment was reasonably subject to contrary assessments of whether the parties intended their signed contract to be the complete embodiment of their agreement. The court remanded the case for a factual hearing before the bench on the integration issue.

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