Pillsbury Co. v. Wells Dairy, Inc.
Iowa Supreme Court
752 N.W.2d 430 (2008)

- Written by Eric Cervone, LLM
Facts
Pillsbury Co. (plaintiff) entered into a production contract with Wells Dairy (Wells) (defendant). Several months later, there was an explosion at Wells’s manufacturing facility where Pillsbury’s product was being made. Pillsbury filed a claim against Wells, alleging breach of contract and negligence. Wells argued that the force-majeure clause of its agreement with Pillsbury excused Wells’s inability to perform. The clause relieved the parties of liability for any delay of performance caused by, in part, explosions or “any other cause that is beyond the reasonable control of the party.” The trial court held that the force-majeure clause was ambiguous because the phrase “that is beyond the reasonable control of the party” could either modify only “other causes,” or it could also modify explosions. The trial court then sustained Wells’s motion for summary judgment. The trial court held that the force-majeure clause protected Wells from liability for any explosion, not just explosions beyond its reasonable control. Pillsbury appealed.
Rule of Law
Issue
Holding and Reasoning (Wiggins, J.)
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