Illinois Central R.R. Co. v. Crail
United States Supreme Court
281 U.S. 57 (1930)
Crail (plaintiff) bought a wholesale carload of coal weighing 88,700 pounds that arrived 5,500 pounds short, and rather than separately replacing that shortage, simply continued purchasing coal in comparable wholesale carload lots at roughly $5.50 per ton plus freight going forward, since his existing stock meant the shortage did not disrupt his business. The trial court nonetheless awarded him damages based on the much higher $13.00-per-ton retail price for coal sold in less-than-carload quantities, and the railroad (defendant) appealed that damages measure.
Whether an aggrieved party in a breach of contract is entitled to the exact market value of the breach measured at the retail price, even if that measure does not reflect the loss the party actually incurred.