Minnesota Supreme Court - 20 Minn. 494
In Stees v. Leonard (1874), the Minnesota Supreme Court dealt with a contract dispute between the plaintiffs and defendants regarding a three-story building that collapsed twice during construction due to poor soil conditions. The plaintiffs wanted compensation for the defendants' inability to complete the building.
The main question was whether the defendants were excused from fulfilling the contract due to soil problems making construction difficult or impossible. The court ruled that the defendants weren't excused and were responsible for damages to the plaintiffs. This was because the defendants took on the risk of any soil issues when they agreed to a fixed-price contract without any contingency clauses. The court also found that the defendants hadn't proven absolute impossibility to build on the soil, just increased difficulty and expense.
This case is important because it highlights the principle of strict performance in contract law, which requires a party to perform exactly what was agreed upon unless prevented by an act of God, the law, or the other party. The case shows that courts won't excuse a party from their contractual obligations based on hardship or impracticability unless specific provisions address these contingencies in the contract. When deciding if a breach is excusable, courts consider the extent of the problem and the intentions and conduct of those involved.
The legal principle is that a contractor must fulfill their contractual obligations, unless prevented by an act of God, the law, or the other party. The law enforces the exact terms of the contract and does not relieve parties from the consequences of their own actions. Recent cases such as Adams vs. Nichols and School Dist. vs. Dauchy have emphasized that any hardship that may arise is a result of the party's own lack of foresight or discretion. If a person makes an unconditional promise to perform a certain task by a specific time, and the task is not impossible or illegal at the time of the promise, then the person is bound by the promise unless the performance becomes illegal before the deadline. The law casts the loss upon the party who has agreed to sustain it, and unexpected impediments do not allow for a contract to be annulled or for terms to be interpolated that were not stipulated by the parties.
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