Machinery v. Steel

• Steel of West Virginia = "Steel" = defendant = steel seller
• Machinery Hauling, Inc. = "Machinery" = plaintiff = delivery company for large business loads
• Steel entered into a contract for Machinery to deliver steel for a 3rd-party
• Shelby Steel, Inc. = "Shelby" = the 3rd party located in Louisville, Kentucky
• After the hauling of steel was complete, Steel told Machinery that the 3rd party (Shelby) had rejected the delivery
• Steel blamed Machinery for the defective loads
• A Steel agent demanded Machinery pay up $31,000 or else Steel would discontinue doing business with Machinery

• Machinery sued Steel for extorting money by threatening to sever business relations.
• Machinery lost.

Can a plaintiff (Machinery) base a claim of economic duress on the expectancy of a future business relationship with the defendant (Steel)?

Machinery placed the value of its business relation with Steel at over $1,000,000 (1 million)/year in 1989.

No. The expectancy of a future business relationship is not a legal right on which a plaintiff may base a claim of economic duress.

Case dismissed

Justice Miller: The 2 parties weren't under an ongoing contract requiring continued business relations.