Sunday, December 1, 2013

Minneapolis & St. Louis Railway Co. v. Columbus Rolling-Mill Co. case brief

Minneapolis & St. Louis Railway Co. v. Columbus Rolling-Mill Co. case brief summary
119 U.S. 149 (1886)

Plaintiff appealed a judgement of the Circuit Court of United States for the Southern District of Ohio finding defendant did not breach any contract between the parties because no contract existed.

  • On December 5, 1879, Minneapolis & St. Louis Railway Co. (P) sent a letter to Columbus Rolling-Mill Co. (D) requesting a quote for the price of 2,000 to 5,000 tons of iron rails. 
  • Columbus replied in a letter sent December 8th, stating that it would sell between 2,000 and 5,000 tons of iron rails for $54.00 per ton. 
  • On December 16th, Minneapolis sent a telegram Columbus with a request of an order of 1,200 tons of iron rails at $54.00 per ton. 
  • On December 18th, Columbus replied by telegram stating that it would not fulfill the order. 
  • On December 19th, Minneapolis sent another telegram to Columbus requesting an order of 2,000 iron rails at $54.00 per ton. 
  • Columbus did not reply to this telegram. 
  • After repeated inquiries by Minneapolis, Columbus denied that any contract existed between the parties on January 19, 1880. 
  • Minneapolis brought suit against Columbus for breach of contract. 
  • The trial court entered judgment for Columbus, and Minneapolis appealed the judgment.
When an offer is made, must the acceptance be based upon the exact terms that are contained in the offer?

  • Plaintiff appealed a judgment of the lower court finding a valid contract did not exist between the parties because plaintiff rejected defendant's offer. 
  • On review, the Court affirmed and found that when plaintiff received defendant's offer to sell to plaintiff between two thousand and five thousand tons of steel, plaintiff rejected the offer by placing an order for twelve hundred tons of steel. 
  • By accepting defendant's offered price, but ordering less than the specified quantity, plaintiff made a qualified acceptance of defendant's offer and thus rejected defendant's offer. 
  • Once plaintiff rejected the offer, the plaintiff could not revive it by accepting defendant's offer. 
  • Defendant's notification to plaintiff that the order could not be filled closed negotiations between the parties.

The Court affirmed the judgment and found since plaintiff did not accept defendant's offer, no contract was formed.

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