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Interstate Industries, Inc. v. Barclay Industries, Inc.

(1976)

United States Court of Appeals for the Seventh Circuit - 540 F.2d 868

Tags: Contracts

tl;dr:

After sending a price quote, a company is unable to fulfill a purchase order, and the customer (another company) sues, claiming that the price quote was an offer such that the purchase order was an acceptance.

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Case Summary

In the case of Interstate Industries, Inc. v. Barclay Industries, Inc. (1976), the Seventh Circuit Court of Appeals handled a breach of contract claim related to fiberglass panel sales. This case was heard at the federal appellate level due to its diversity jurisdiction and an interlocutory appeal from a lower court's refusal to dismiss the case.

Interstate Industries, an Indiana company, bought fiberglass panels from Barclay Industries, a Delaware company with offices in New Jersey. Barclay sent Interstate a letter offering their new fiberglass panels' prices but provided no details about quantity, delivery time, or payment terms. Interstate responded with two purchase orders for the new panels, stating "F.O.B. Delvd." Barclay later told Interstate it couldn't supply the panels, leading to a lawsuit in an Indiana federal court. Barclay argued that the court lacked personal jurisdiction over the company, but the district court denied their motion and permitted an interlocutory appeal.

The Court of Appeals reversed the decision, stating there was no personal jurisdiction and no valid contract as there was no offer and acceptance. The court deemed Barclay's letter as a price quotation, not an offer, and Interstate's purchase orders as unaccepted offers.

This case emphasizes legal principles surrounding contract formation and interpretation, including offer and acceptance, price quotation, term definiteness, and personal jurisdiction in contract disputes. It's relevant for anyone dealing with contracts and understanding their rights and obligations in case of an offer or a claim.

ICRAIssue, Conclusion, Rule, Analysis for Interstate Industries, Inc. v. Barclay Industries, Inc.

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Facts & HoldingInterstate Industries, Inc. v. Barclay Industries, Inc. case brief facts & holding

Facts:Appellant Barclay and Appellee Interstate were involved in transactions over...

Holding:The price quotation letter sent from Barclay to Interstate was...

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Interstate Industries, Inc. v. Barclay Industries, Inc. | Case Brief DeepDive
Majority opinion, author: SPRECHER, Circuit Judge.
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Interstate Industries, Inc. is suing Barclay Industries, Inc. for breach of contract. The district court found that it had personal jurisdiction over Barclay based on Indiana Trial Rule 4.4(A)(1) and that Barclay had sufficient minimum contacts with Indiana. The court reaffirmed its decision in response to Barclay's motion to reconsider, finding that a "destination" contract existed to supply goods or materials to be furnished in Indiana. The issue is whether the correspondence between the parties constituted an enforceable contract to deliver goods in Indiana, which will be determined by Section 2-204 of the Uniform Commercial Code. To form a contract, there must be a meeting of the minds or a manifestation of mutual assent by the parties to an informal contract, done with the intent to do those acts. The law requires a meeting of minds for a contract to come into being. The lower court used Indiana Trial Rule 4.4 to determine personal jurisdiction over Barclay, but it erred in its decision.

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