Globe Refining Co. v. Landa Cotton Oil Co. case brief
Globe Refining Co. v. Landa Cotton Oil Co. case brief summary
190 U.S. 540 (1903)
Plaintiff in error, a buyer, sought
review of a judgment from the Circuit Court of the United States for
the Western District of Texas, which dismissed its suit, for breach
of a contract to sell and deliver crude oil, for lack of jurisdiction
because plaintiff in error had fraudulently magnified the damages to
meet the jurisdictional requirements.
CASE FACTS The Court affirmed a judgment that
dismissed an action for breach of contract. The defendant in error
seller alleged that plaintiff in error buyer claimed damages in
excess of lost profits in order to fraudulently give the circuit
court jurisdiction. The contract was for the sale of oil. Plaintiff
in error claimed damages for payment to the railroad to ship the oil,
the travel of railroad cars in excess of 1,000 miles prior to notice
of the breach, the loss of the use of its oil tanks for 30 days, its
promises to customers to furnish oil within a certain time, and the
loss of customers, credit, and reputation.
The Court held that
defendant in error was only liable for damages that were contemplated
by the contract or that plaintiff in error could have reasonably
expected them to contemplate.
The Court stated that mere notice to a
seller of some interest or probable action of the buyer was not
enough to charge the seller with special damages on that account if
he failed to deliver the goods.
The Court agreed with the trial court
that none of the special damages were reasonably contemplated by the
The Court affirmed the judgment and held that defendant in error
could only be held responsible for damages that plaintiff in error
could have reasonably contemplated at the time of contract. Finding
that none of the special damages could have been reasonably
contemplated, the Court affirmed the dismissal of the case. Suggested law school study materials
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