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


  • 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.


Are consequential damages only recoverable if they're reasonably foreseeable, ascertainable, & un-avoidable?


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.


Reversed the amount of consequential damages. The jury's award of damages needs to be reduced