Machinery v. Steel

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Machinery v. Steel
Court West Virginia Supreme Court of Appeals
Citation 384 S.E.2d 139
Date decided July 27, 1989


  • 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.


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.