Columbia Nitrogen Corp. v. Royster Co.
United States Court of Appeals for the Fourth Circuit
451 F.2d 3 (1971)
- Written by Christine Hilgeman, JD
Facts
Columbia Nitrogen Corp. (Columbia) (defendant), a nitrogen and mixed fertilizer manufacturer, sold its products to Royster Co. (Royster) (plaintiff) for several years. In 1966, Royster began to manufacture phosphate. Columbia agreed to purchase a minimum amount from Royster for three years. The contract set the price per ton and contained a merger clause that excluded any “verbal understanding” from the terms of the contract. When phosphate prices dropped steeply in the first year of the contract, Columbia failed to purchase the agreed amount and Royster was forced to sell the remaining phosphate at a lower price. Royster sued Columbia for damages. Columbia attempted to present evidence showing that Columbia and Royster, in their prior dealings, often deviated from the contract price. Columbia also proffered evidence that price and quantity terms in the mixed fertilizer industry were treated as projections and were subject to modification according to market fluctuations. The district court excluded Columbia’s evidence of prior dealing and trade usage. Judgment was entered for Royster and Columbia appealed the district court’s exclusion of its evidence.
Rule of Law
Issue
Holding and Reasoning (Butzner, J.)
What to do next…
Here's why 805,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.
