Hydraform v. American Steel
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| Hydraform v. American Steel | |
| Court | New Hampshire Supreme Court |
|---|---|
| Citation | 498 A.2d 339 |
| Date decided | August 16, 1985 |
Facts
- American Steel & Aluminum Corp. = steel producer = "American" = defendant
- Hydraform Products Corp. = "Hydraform" = plaintiff= manufacturer of steel woodstoves
- In July 1978, Hydraform contracted to buy steel to make 400 (four hundred) stoves from American
- Time was critical in the manufacturing of stoves.
- American's deliveries were late & some steel was defective
- As a result, Hydraform manufactured only 250 stoves--thus losing profits
Procedural History
The jury found in favor of Hydraform in the Superior Court in New Hampshire.
Issues
Are consequential damages only recoverable if they're reasonably foreseeable, ascertainable, & un-avoidable?
Holding
Yes. A party can only recover consequential damages if the damages are reasonably foreseeable, ascertainable, & un-avoidable.
David Souter: Hydraform is entitled to buyer's damages, including consequential damages.
Hydraform can only recover for that 1 year--not future years.Judgment
Reversed the amount of consequential damages. The jury's award of damages needs to be reduced
Resources
