Minnesota Linseed Oil Co. v. Collier White Lead Co.

Minnesota Linseed Oil Company (Minnesota) (plaintiff) originally sued Collier White Lead Company (Collier) (defendant) for $2,151 in a dispute arising from a contract. Collier, in turn, filed a counterclaim on a separate contract. Regarding its counterclaim, Collier alleged that the parties entered into a binding contract on August 3, 1875, whereby Minnesota would sell to Collier 12,450 gallons of linseed oil for the price of 58 cents per gallon. Collier further alleged that Minnesota breached this contract by failing to deliver the oil. Finally, Collier argued that because the market value of linseed oil had risen to 70 cents per gallon by August 3, it was entitled to damages stemming from Minnesota’s refusal to sell the oil at 58 cents per gallon. Notably, the transaction had been negotiated by telegraph in the following manner: (1) on July 29, Minnesota solicited an offer for the sale of oil from Collier, (2) on July 30, Collier requested 300 barrels for 55 cents per gallon, (3) on July 31, Minnesota transmitted a telegraph offering to sell the requested oil at 58 cents per gallon, but this message was allegedly not delivered to Collier until August 2, (4) on August 3, Collier accepted the offer of 58 cents per gallon by telegraph, (5) on August 3, Minnesota attempted to revoke its offer, but Collier asserted that the sale was complete before any withdrawal was received. Minnesota argued that there was no contract binding the parties to this transaction because Collier’s acceptance was not offered within a reasonable time of the offer.