Minneapolis v. Columbus: Difference between revisions

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{{Infobox Case Brief
{{Infobox Case Brief
|court=Supreme Court of the United States
|court=Supreme Court of the United States
|citation=119 U.S. 149
|date=November 29, 1886
|date=November 29, 1886
|subject=Contracts
|subject=Contracts
|other_subjects=Business Associations
|facts=*Minneapolis & St. Louis Railway Co. = "Minneapolis" = plaintiff = a train company based in Minnesota = a company needing iron for its railways = iron buyer
|facts=*Minneapolis & St. Louis Railway Co. = "Minneapolis" = plaintiff = a train company based in Minnesota = a company needing iron for its railways = iron buyer
*Columbus Rolling-Mill Co.  = "Columbus" = defendant = an iron manufacturer = iron seller
*Columbus Rolling-Mill Co.  = "Columbus" = defendant = an iron manufacturer in Ohio = iron seller
*On December 5, 1879, Minneapolis wrote a letter to Columbus requesting a quote for the price of 2,000 to 5,000 tons of iron rails.
*On December 5, 1879, Minneapolis wrote a letter to Columbus requesting a quote for the price of 2,000 to 5,000 tons of iron rails.
*Columbus offered to sell irons to Minneapolis for $54/ton if such large quantity was needed.
*Columbus offered to sell irons to Minneapolis for $54/ton if such large quantity was needed.
*Subsequently, Columbus became un-responsive to several letters from the buyer Minneapolis.
*Subsequently, Columbus became un-responsive to several letters from the buyer Minneapolis.
*Finally, on January 19th 1880, Columbus announced that there was no contract.
*Finally, on January 19th 1880, Columbus announced that there was no contract.
*
*'''Timeline''':
*
{{Timeline
|procedural_history=* Minneapolis sued Columbus in federal district court.  
|quote requested<br />by Minneapolis
* Minneapolis sought to enforce a December 19th 1879 contract for 2,000 tons of iron rails at $54/ton.
|Dec. 5
|Dec. 8
|$54/ton<br />quote provided<br />by Columbus
|order placed for<br />1,200 tons
|Dec. 16
|Dec. 18
|order canceled<br />for 1,200 tons
|order placed for<br />2,000 tons
|Dec. 19
|Dec. 22
|Inquiry re: order
|Communication that no contract was formed
|Jan. 19
}}
|procedural_history=*Minneapolis sued Columbus in federal district court.
*Minneapolis sought to enforce a December 19th 1879 contract for 2,000 tons of iron rails at $54/ton.
*The trial jury decided in favor of Columbus (iron producer).
|issues=Does an offer have to be accepted [[Contracts/Mirror image rule|according to its exact terms]] in order to form a binding contract?
|arguments=Columbus contended that there was no contract.
|holding=Yes. An offer must be accepted according to its exact terms in order to form a binding obligation.
|judgment=Affirmed
|case_text_links={{Infobox Case Brief/Case Text Link
|case_text_links={{Infobox Case Brief/Case Text Link
|link=https://www.quimbee.com/cases/minneapolis-amp-st-louis-railway-co-v-columbus-rolling-mill-co
|link=https://www.quimbee.com/cases/minneapolis-amp-st-louis-railway-co-v-columbus-rolling-mill-co

Latest revision as of 04:05, December 16, 2023

Minneapolis v. Columbus
Court Supreme Court of the United States
Citation 119 U.S. 149
Date decided November 29, 1886

Facts

  • Minneapolis & St. Louis Railway Co. = "Minneapolis" = plaintiff = a train company based in Minnesota = a company needing iron for its railways = iron buyer
  • Columbus Rolling-Mill Co. = "Columbus" = defendant = an iron manufacturer in Ohio = iron seller
  • On December 5, 1879, Minneapolis wrote a letter to Columbus requesting a quote for the price of 2,000 to 5,000 tons of iron rails.
  • Columbus offered to sell irons to Minneapolis for $54/ton if such large quantity was needed.
  • Subsequently, Columbus became un-responsive to several letters from the buyer Minneapolis.
  • Finally, on January 19th 1880, Columbus announced that there was no contract.
  • Timeline:
Dec. 5
quote requested
by Minneapolis
Dec. 8
$54/ton
quote provided
by Columbus
Dec. 16
order placed for
1,200 tons
Dec. 18
order canceled
for 1,200 tons
Dec. 19
order placed for
2,000 tons
Dec. 22
Inquiry re: order
Jan. 19
Communication that no contract was formed


Procedural History

  • Minneapolis sued Columbus in federal district court.
  • Minneapolis sought to enforce a December 19th 1879 contract for 2,000 tons of iron rails at $54/ton.
  • The trial jury decided in favor of Columbus (iron producer).

Issues

Does an offer have to be accepted according to its exact terms in order to form a binding contract?

Arguments

Columbus contended that there was no contract.

Holding

Yes. An offer must be accepted according to its exact terms in order to form a binding obligation.

Judgment

Affirmed

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