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J.D. Fields & Company, Inc. v. United States Steel International, Inc.

United States Court of Appeals for the Fifth Circuit
426 Fed. Appx. 271 (2011)


Facts

J.D. Fields & Company, Inc. (plaintiff), purchased steel on an ongoing basis from United States Steel International, Inc. (USSI) (defendant). Generally, Fields would first request a price quote; USSI would respond with a quote; Fields would respond with a purchase order; and USSI would respond with an order confirmation. Two steel orders are relevant to this case. For the first order, USSI quoted a price but stated that the order had to be for a minimum of 100 tons of steel at the quoted price. Fields responded with an order for 880 feet of steel pipe, which weighed approximately 60 tons. The parties exchanged various emails thereafter, with Fields eventually stating that “if need be, we will go up to 100 tons.” Fields, however, did not send a revised purchase order. For the second order, USSI sent Fields a detailed price quote, containing the specific product, price, quantity, delivery time frame, and expiration date. Fields responded with a purchase order, but USSI did not send an order confirmation and never filled the order. In each case, USSI did not deliver the steel under discussion. Fields sued for breach of contract, claiming that the parties formed a valid contract for each of the orders and that USSI breached the contracts by failing to deliver the steel. The district court granted USSI’s motion for summary judgment. Fields appealed.

Rule of Law

Issue

Holding and Reasoning (Aycock, J.)

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