Minneapolis v. Columbus

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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.
  • File:Minneapolis v. Columbus (SCOTUS 1886).png
    Timeline in late 1879 & Jan. 1880

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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