J.D. Fields & Company, Inc. v. United States Steel International, Inc.
United States Court of Appeals for the Fifth Circuit
426 Fed. Appx. 271 (2011)
Fields (plaintiff) regularly bought steel from USSI (defendant) through a request-quote-order-confirmation cycle. For a first order, USSI quoted a price conditioned on a 100-ton minimum, but Fields ordered only about 60 tons and never submitted a revised purchase order matching the minimum, though it later said by email it would go up to 100 tons if needed. For a second order, USSI sent Fields a detailed quote with product, price, quantity, delivery date, and expiration, and Fields responded with a matching purchase order, but USSI never confirmed and never delivered either order. Fields sued for breach of contract on both orders; the district court granted USSI summary judgment on both, and Fields appealed.
Whether a detailed price quotation can constitute an offer when the offeree reasonably believes that assenting to the quote will form a binding contract.