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Autotrol Corp. v. Continental Water Systems Corp.

United States Court of Appeals for the Seventh Circuit

918 F.2d 689 (7th Cir. 1990)

Relevant factsFree

In 1986, Autotrol (plaintiff) and Continental (defendant) contracted for Autotrol to manufacture and sell water purification systems. Autotrol was a growing company with a steady stream of profitable projects. Continental terminated the contract the following year, and Autotrol sued for breach and won. A jury awarded Autotrol $245,000 in out-of-pocket expenses and over $700,000 in overhead expenses. Continental appealed only the overhead award.

IssueFree

Whether overhead expenses lost to a breached contract are recoverable as damages when there is a reasonable probability the injured party could have recovered those expenses through an alternative contract.

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