Laclede Gas Co. v. Amoco Oil Co.
United States Court of Appeals for the Eighth Circuit
522 F.2d 33 (8th Cir. 1975)
Laclede Gas Co. (plaintiff) and Amoco Oil Co. (defendant) entered a requirements-style agreement under which Laclede would supply propane gas systems to individuals and developers, sourcing the gas from Amoco; the contract automatically renewed yearly unless Laclede gave Amoco 30 days' written notice before a renewal date, but the contract gave Amoco no equivalent right to cancel. After Amoco raised its propane price and Laclede objected and demanded an explanation, Amoco instead sent notice that it was terminating the agreement altogether, claiming the contract was void for lack of mutuality since only Laclede could cancel. The district court agreed and found the contract void, and Laclede appealed.
Whether a contract is rendered void for lack of mutuality when only one party holds a right of cancellation, and whether specific performance is available when a court can determine each party's duties with reasonable certainty.