Maritime-Ontario Freight Lines, Ltd. v. STI Holdings, Inc.

481 F. Supp. 2d 963 (2007)

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Maritime-Ontario Freight Lines, Ltd. v. STI Holdings, Inc.

United States District Court for the Western District of Wisconsin
481 F. Supp. 2d 963 (2007)

Facts

On July 30, 2001, STI Holdings, Inc. (Stoughton) (defendant) prepared a report (the thermal-performance report) for Maritime-Ontario Freight Lines, Ltd. (Maritime) regarding a thermal-performance review for its shipping containers. In the thermal-performance report, Stoughton represented that the thermal performance of its shipping containers was presumed to be approximately 400 BTU/hr/F, which was above industry standards. On May 30, 2002, Maritime entered into an agreement with Stoughton to purchase 200 of Stoughton’s shipping containers. The agreement contained detailed design specifications and incorporated industry standards. However, the agreement contained nothing about thermal performance and nothing about the thermal-performance report. The agreement included a limited warranty, which specifically stated that any suggestions by Stoughton regarding the use, application, or suitability of the goods or services would not be construed as an express warranty unless confirmed to be such in writing by Stoughton. Moreover, the agreement included an unambiguous integration clause. Thereafter, Maritime experienced problems with the shipping containers it purchased. Stoughton refused to fix the shipping containers and alleged that the problems were operational failures not covered under any warranty. Maritime sued Stoughton for breach of warranty regarding both the thermal performance of the shipping containers and alleged structural defects with the shipping containers. Maritime conceded that the shipping containers complied with the product specifications in the agreement but supported its thermal-performance claim with the thermal-performance report. Stoughton argued that Maritime’s thermal-performance claim was barred by the agreement’s integration clause and moved for summary judgment on that claim.

Rule of Law

Issue

Holding and Reasoning (Shabaz, J.)

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