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Betaco, Inc. v. Cessna Aircraft, Co.

Seventh Circuit Court of Appeals
32 F.3d 1126 (1994)


Facts

In 1990, Betaco, Incorporated (Betaco) (plaintiff) was interested in purchasing the CitationJet from Cessna Aircraft Company (Cessna) (defendant). On January 25, 1990, Cessna forwarded information about the CitationJet. The information included a cover letter, which stated that the CitationJet “has more range than the popular Citation I.” The packet also included a purchase order that contained detailed specifications about the CitationJet, as well as an integration clause stating that the purchase order represented the parties’ entire agreement. Betaco signed the purchase order and put down a $150,000 deposit. After one of Betaco’s employees analyzed the CitationJet, the employee informed Betaco that the CitationJet did not have more range than the Citation I. Betaco sought to cancel the contract and a return of the $150,000 deposit. Cessna refused and Betaco brought suit arguing that the cover letter was an express warranty that Cessna breached. The trial court granted summary judgment in favor of Betaco on the issue of integration stating that the purchase order was not a fully integrated document and the cover letter should be construed as part of the contract. Cessna appealed.

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Holding and Reasoning (Rovner, J.)

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