Bolin Farms v. American Cotton Shippers Association

Bolin Farms and other cotton farmers (plaintiffs) entered forward sales contracts with American Cotton Shippers Association (defendant), agreeing to sell all future cotton from set acreage at a fixed price. When the contracts were formed, cotton was 29-41 cents per pound; market factors then drove the price to 80 cents. Bolin Farms sued for a declaratory judgment that the price swing made the contracts unenforceable. Thirteen similar suits against the defendant had already been held to yield enforceable contracts.

Whether a change in market circumstances after a forward sales contract is formed renders the contract unenforceable.