Jetz Service Co. v. Salina Properties

Jetz Service (plaintiff) leased coin-operated laundry machines to Salina Properties (defendant), maintaining roughly 1,500 washers and dryers across several warehouses and constantly seeking new placement locations for its equipment. With 16 months remaining on the lease, Salina disconnected all of Jetz's machines and replaced them with its own; Jetz recovered its equipment, re-leased some but not all of it elsewhere (including to a Kansas City location), and sued Salina for lost profits. Salina argued Jetz failed to mitigate its damages by fully re-leasing the machines; the trial court found Jetz was a "lost-volume seller" and ruled in its favor, and Salina appealed.