Betaco, Inc. v. Cessna Aircraft, Co.
Seventh Circuit Court of Appeals
32 F.3d 1126 (1994)
Betaco (plaintiff) wanted to buy Cessna's CitationJet, and Cessna's (defendant) cover letter promoting the plane claimed it "has more range than the popular Citation I." The purchase order Betaco then signed contained detailed range specifications and an integration clause stating it represented the entire agreement; Betaco put down a $150,000 deposit. After Betaco's own engineer found the CitationJet did not actually have more range than the Citation I, Betaco tried to cancel and get its deposit back, then sued for breach of an express warranty based on the cover letter. The trial court granted Betaco summary judgment, ruling the purchase order was not fully integrated and the cover letter's promise was part of the deal; Cessna appealed.
Whether, under the UCC, a court must look beyond the four corners of a contract to the surrounding circumstances — including the parties' words and conduct — to determine whether they intended the contract to be fully integrated.