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.
- Timeline:
Dec. 5
quote requestedby Minneapolis
Dec. 8
$54/tonquote provided
by Columbus
Dec. 16
order placed for1,200 tons
Dec. 18
order canceledfor 1,200 tons
Dec. 19
order placed for2,000 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
