Thursday, December 26, 2013

PFT Roberson, Inc. v. Volvo Trucks North America, Inc. case brief

PFT Roberson, Inc. v. Volvo Trucks North America, Inc. case brief summary
420 F.3d 728 (2005)

Plaintiff truck fleet operator filed an action against defendants, a truck company and a related transportation services company, alleging breach of contract and fraud claims. The parties filed cross-appeals after the United States District Court for the Central District of Illinois accepted a jury verdict in the operator's favor and denied defendants' motion for judgment as a matter of law under Fed. R. Civ. P. 50.

The parties entered into negotiations concerning a fleet agreement. Although a number of lengthy draft agreements were exchanged, none of them were ever signed. The operator alleged that a 572 word e-mail message constituted a contract between the parties, that defendants had breached that contract, and that defendants had engaged in fraud by attempting to change the terms of the contract after the message was sent.


  • The district court submitted only the breach of contract issue to the jury; it found in the operator's favor. 
  • The court held that the breach of contract issue should not have been given to the jury and that the dispute should have been resolved by the entry of summary judgment in defendants' favor.
  • The parties were negotiating a comprehensive arrangement, not a series of stand-alone contracts. 
  • No reasonable jury could conclude that the message, which recapped the parties' negotiations, identified items that had been agreed upon, and listed other items that needed to be reviewed and finalized, constituted a contract or that the agreed-upon items were independent bargains to which defendants bound themselves. 
  • It was unnecessary to consider the operator's fraud claim.

The court reversed the district court's judgment.

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