Friday, December 27, 2013

Mesaros v. United States case brief

Mesaros v. United States case brief summary
845 F.2d 1576 (1988)

Plaintiff numismatists appealed a judgment that the United States District Court for the Southern District of Georgia, Savannah Division, summarily entered in favor of defendant federal government in litigation arising under the Statue of Liberty-Ellis Island Commemorative Coin Act (Act), Pub. L. No. 99-61, 99 Stat. 113 (1985).

The Act authorized the U.S. Mint to strike specific quantities of three types of commemorative coins depicting the national landmark. The federal government processed the cash sale orders of other buyers before honoring the numismatists' orders to be billed to credit cards, with the consequence that the statutory run of production was exhausted before the numismatists' orders were filled. The numismatists, therefore, filed suit in breach of contract, seeking equitable relief. The trial court granted the federal government's motion in the alternative for summary judgment or to dismiss the numismatists' complaint.

  • On the numismatists' appeal, the court held that the trial court's ruling was proper. 
  • The court noted that it was generally unreasonable for a person to consider advertisements and solicitations as offers that bound the advertiser. 
  • More specifically, the federal government's advertising materials could only be reasonably construed as invitations to bargain rather than firm offers enforceable against the federal government. 
  • The Act did not require that orders be filled in any particular order. 
  • The courts had no constitutional authority to decree that more coins be produced.
The court affirmed the judgment of the trial court that disposed of the numismatists' suit against the federal government.

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