Helena Chemical Co. v. Williamson

United States District Court for the Western District of Louisiana

2015 WL 1298435 (W.D. La. 2015)

Commercial parties may limit or exclude consequential damages so long as the limitation or exclusion is not unconscionable.

Relevant Facts

Lavelle Williamson (the defendant) entered into a contract with Helena Chemical Company (the plaintiff), whereby the defendant agreed to purchase corn seed, fertilizer, and chemicals. The agreement included a provision waiving any and all claims against the plaintiff for consequential damages. The defendant never had experience farming, and had only a 10th grade education. Subsequently, the defendant’s crop failed to grow and the defendant stopped making payments on the contract. The plaintiff sued, seeking to recover the payments due under the contract. The defendant counterclaimed on the grounds of negligence, contending that the corn seed was already wet when he received it. The defendant sought consequential damages. The plaintiff filed a motion for summary judgment on the defendant’s counterclaim, relying on the provision in the contract that excluded consequential damages.

Issue

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Holding & Reasoning

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Concurrence

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Dissent

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Last updated:

December 20, 2020

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Procedural History

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Citations

2015 WL 1298435 (W.D. La. 2015)