Machinery v. Steel

From wikilawschool.org. Wiki Law School does not provide legal advice. For educational purposes only.
Machinery v. Steel
Court West Virginia Supreme Court of Appeals
Citation 384 S.E.2d 139
Date decided July 27, 1989

Facts

  • 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

Procedural History

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

Issues

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

Arguments

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

Holding

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

Judgment

Case dismissed

Reasons

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

Resources