Warning

Info

Table of Contents
Jawshu, CLS '24 |

0 0

Back to briefs

Monetti v. Anchor Hocking Corp.

(1991)

United States Court of Appeals for the Seventh Circuit - 931 F.2d 1178

tl;dr:

A company agreed to become the distributor for another company, but then breached. Even though they did not sign a contract, they were held liable because they had signed other written proof of the agreement.

Video Summary


Case Summary

Monetti v. Anchor Hocking Corp. (1991) dealt with a contract dispute involving food service product distribution.

Anchor Hocking was to become the sole distributor in the United States for Monetti’s food service products for a ten-year period. During negotiations, Monetti sent Anchor Hocking a draft agreement, which Anchor Hocking did not sign. However, Anchor Hocking did prepare two memos indicating nearly all terms of the agreement. The first was a memo initialed by Anchor Hocking’s agent before the agreement was finalized, and the second was an internal memo written by Anchor Hocking’s marketing director on company letterhead. After the first memo was written, Monetti turned over its entire distribution operation in the U.S. to Anchor Hocking, but after the second memo was written, the relationship between Monetti and Anchor Hocking began to deteriorate.

Eventually Monetti sued for breach of contract and Anchor Hocking raised the statute of frauds as a defense. The trial court agreed that the suit was invalid due to the Uniform Commercial Code (UCC) statute of frauds, which requires written evidence of contracts for the sale of goods worth at least $500. Monetti appealed.

The appeal court held that the letter agreement satisfied the statute of frauds and was enforceable. The agreement contained essential contract terms, such as price, quantity, duration, and exclusivity. It also expressed a clear intention to be bound by its terms, stating it was a "summary agreement" and would be "reduced to a definitive agreement" later. Unilateral performance applied because the plaintiff relied heavily on the contract, having ended its previous distributor relationship and transferring distribution operations to the defendant. Equitable estoppel applied because the defendant made an oral promise intended for the plaintiff to rely on, causing the plaintiff to change his position.

This case highlights the principle of definiteness in contract law, the need for a sufficient writing to enforce contracts, and how courts use equitable doctrines to prevent injustice or fraud in contract enforcement. Courts look at the parties' language, actions, and the contract's nature and purpose to determine if the parties intended to be bound.

ICRAIssue, Conclusion, Rule, Analysis for Monetti v. Anchor Hocking Corp.

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Monetti v. Anchor Hocking Corp. case brief summary.

Enjoy unlimited access with our 14-day free trial.

Facts & HoldingMonetti v. Anchor Hocking Corp. case brief facts & holding

Facts:Monetti, S.P.A. (plaintiff) sued Anchor Hocking Corp. (defendant) for breach...

Holding:There is nothing under the UCC statute of frauds that...

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Monetti v. Anchor Hocking Corp. case brief summary.

Enjoy unlimited access with our 14-day free trial.

DeepDiveHighlight a legal term to see the definition

Font size -+
Monetti v. Anchor Hocking Corp. | Case Brief DeepDive
Majority opinion, author: POSNER, Circuit Judge.
Level 1
Click below 👇 to DeepDive

This case involves a breach of contract lawsuit governed by Illinois law. Monetti granted exclusive distribution rights to the Schneiders for its products in the U.S. and transferred Melform's assets to them. Monetti terminated Melform's distributors and informed its customers that Anchor Hocking would become the exclusive U.S. distributor of Monetti's products. The lower court dismissed the suit due to the statute of frauds and denied the plaintiffs' request to add a claim of promissory estoppel. The appeal challenges both rulings and raises important questions regarding the general Illinois statute of frauds and the Uniform Commercial Code's statute of frauds. The court ruled that oral evidence cannot be used to satisfy the statutes of frauds, as it would defeat the purpose of requiring a written agreement. A precontractual writing indicating the promisor's acceptance of the promisee's offer, with all essential terms stated, can satisfy the statute of frauds, even if the writing was prepared before the contract became final. Steve Schneider's "Topics for Discussion" memo with its "Attachment #1" satisfies the statute of frauds because Schneider's typed initials meet the requirement of being executed or adopted by the defendant. The use of the perfect tense in the Uniform Commercial Code is a potential issue, but a memorandum satisfying the statute may be made before the contract is concluded under a general statute of frauds. The lower court erred in dismissing the suit due to the statute of frauds and denying the plaintiffs' request to add a claim of promissory estoppel.

Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Monetti v. Anchor Hocking Corp. case brief summary.

Enjoy unlimited access with our 14-day free trial.

🤯 High points 🤯Key points contributed by students on LSD

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Monetti v. Anchor Hocking Corp. case brief summary.

Enjoy unlimited access with our 14-day free trial.

LSD+ Case Briefs

Features

  • DeepDive for detailed case analysis
  • Over 50,000 existing case briefs
  • Instant briefs for another 6,000,000 cases
  • Highlight dictionary for legal term definitions
  • Social learning with chat and high points

Over 50,000 Cases Briefed

LSD+ gives you access to over 50,000 case briefs, more than anyone else. Be the first to email us the website of a case brief product that offers you more case briefs and we'll give you a free year of LSD+.

14-Day Free Trial

Unlimited access. Read as much content as you want during your trial with no device limitations. Cancel any time during your trial and keep access for the full 14 days.

Integrated Legal Dictionary

Lawyers and judges love to use big words. And Latin, for some reason.

Highlight a legal term in LSD Briefs and get an instant, plain English definition. Try highlighting contract or specific performance. No need to search or read through a list of definitions, simply highlight the words you don’t know and our LSDefine integration will instantly give you a definition to any of over 30,000 legal terms.

DeepDive

DeepDive allows you to explore legal cases like never before. DeepDive offers multiple levels of case summaries, which empowers you to quickly and easily find the information you need to stay on top of readings. Easily navigate through summary levels and click on any text to get more detail, all the way down to the original legal case text.

Brief anything. Instantly.

Our proprietary state-of-the-art system can instantly brief over 6,000,000 US cases. That means we can probably brief that case that your professor assigned last night when she sent you a poorly scanned pdf and told you to read every third paragraph. Or maybe she uploaded it to Canvas and didn’t really tell you to read it, but you know you probably should. Tenure does wild things to good people.

Social Learning with Chat and High Points

Study groups are a great way to learn and explore a case. LSD has chat rooms for each case to let you ask questions across the community and hear what other students struggled with and how they put it all together. Learn the key points of every case from other LSD+ users and share your knowledge with LSD High Points.

Real-Time Brief Feedback

Don’t settle for mistakes in briefs that have been there for 10 years and never fixed. Find an issue or something missing from a brief? Down vote and we will make improvements. All of our case brief editors graduated from from T14 law schools.

Monetti v. Anchor Hocking Corp.

Chat for Monetti v. Anchor Hocking Corp.
brief-66
👍 Chat vibe: 0 👎
Help us make LSD better!
Tell us what's important to you
LSD+ is ad-free, with DMs, discounts, case briefs & more.