United States Court of Appeals for the Eighth Circuit - 195 F.2d 977
In the 1952 case, Reliance Cooperage Corp. v. Treat, the Eighth Circuit U.S. Court of Appeals addressed a contract disagreement between a barrel-maker and a wood supplier. Reliance Cooperage had agreed to buy 300,000 wooden staves from Treat for $450 per thousand, with delivery no later than December 31, 1950. However, Treat informed Reliance in September 1950 that he couldn't deliver as promised. Reliance demanded performance, but Treat didn't deliver, leading to a lawsuit for breach of contract and damages.
The district court ruled in favor of Reliance, awarding $12,000 in damages based on the price difference between the contract and market value at the time Reliance learned about Treat's non-performance. The court also emphasized Reliance's responsibility to find a new supplier.
Reliance appealed, and the appellate court reversed the decision, ordering a new trial for determining damages. The court stated that Reliance didn't need to find a new supplier immediately and could wait until the contract delivery date to claim damages based on the price difference.
The case is significant as it demonstrates the legal concept of anticipatory repudiation and how courts handle breach of contract, damage assessments, and damage reduction in contract disputes. It's important for anyone involved with contracts to understand their rights and obligations in case of a breach or potential breach.
This case involves a contract dispute between Reliance Cooperage Corporation and A.R. Treat over the sale of staves. The defendant admitted to not fulfilling the contract due to high costs. The plaintiff seeks damages of $90,000, and evidence shows that the market price of staves had increased between the contract date and the performance due date. The court denied the plaintiff's request to award the difference between the contract price and the market price of staves. The jury was instructed to determine if the defendant had breached the contract before December 31, 1950, and if so, when, and whether the plaintiff could have mitigated damages by purchasing staves on the open market. If the plaintiff could have purchased staves on the open market at a price equal to the contract price, they were entitled to nominal damages only. If the plaintiff could have purchased staves on the open market at a price higher than the contract price, they were entitled to damages for the difference between the market price and the contract price. If the jury did not find a breach of contract by the defendant before December 31, 1950, the plaintiff was entitled to damages for the difference between the market price and the contract price. The contract is governed by the laws of the State of Missouri. The plaintiff's objection to the evidence of market value may have been in error.
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+.
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.
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 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.
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.
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.
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.