New York Central Iron Works Co. v. United States Radiator Co. case brief

New York Central Iron Works Co. v. United States Radiator Co. case brief summary
66 N.E. 967 (1903)

CASE SYNOPSIS

Defendant sought review from a judgment of the Appellate Division of the Supreme Court in the fourth judicial department (New York), which affirmed a judgment in favor of plaintiff entered upon the report of a referee.

CASE FACTS
In the underlying action, plaintiff sought to recover damages for the breach of a written executory contract between the parties for the sale and delivery of goods. The contract was an open one as to the quantity of goods that defendant was to deliver. When plaintiff ordered significantly more goods than usual, defendant refused to provide the additional goods. Defendant construed the contract as calling for only the usual amount of goods and not materially exceeding the quantity delivered in any one year before under a similar contract. Defendant claimed that there was a mutual mistake in framing the contract, and defendant asked that the contract be reformed in this respect. The trial court found for the plaintiff, and defendant appealed.

DISCUSSION

• On appeal, defendant argued that a limitation of quantity was necessarily imported into the contract and that it should be construed as containing it. 
• The court rejected that argument and affirmed the lower court's judgment. 
• The court determined that the parties intentionally left the contract open and indefinite as to the quantity of goods that the plaintiff might order from time to time.

CONCLUSION
The court affirmed the lower court's judgment, which affirmed a judgment in favor of plaintiff entered upon the report of a referee.

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