Bolin Farms v. American Cotton Shippers Association

United States District Court for the Western District of Louisiana

370 F.Supp. 1353 (W.D. La. 1974)

A change in circumstances following entry into a forward sales contract does not render a contract unenforceable.

Relevant Facts

Bolin Farms (the plaintiff) and other cotton farmers entered into forward sales contracts with American Cotton Shippers Association (the defendant). The defendant agreed to purchase for an agreed-upon price all the future cotton produced by the plaintiff on a set amount of acreage. At the time the contract was formed, the market price of cotton was between 29 and 41 cents per pound. However, due to a variety of environmental and market factors, the price rose to 80 cents per pound. The plaintiff brought suit in United States district court, seeking a declaratory judgment that the contract was unenforceable based on the extreme price fluctuations. Thirteen other suits were filed on the same basis as against the defendant prior to the plaintiff’s suit. The court held the contracts enforceable in all thirteen.

Issue

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Holding & Reasoning

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Concurrence

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Dissent

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Last updated:

December 29, 2020

Judicial Opinion

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Procedural History

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Citations

370 F.Supp. 1353 (W.D. La. 1974)