Machinery Hauling, Inc. v. Steel of West Virginia
Supreme Court of Appeals of West Virginia
384 S.E.2d 139 (1989)
Machinery Hauling, Inc. (Machinery) (plaintiff) was contracted by Steel of West Virginia (Steel) (defendant) to transport 17 loads of steel, but near completion Steel claimed the steel was defective and rejected by the buyer, demanding Machinery return the remaining loads and pay $31,000 for the undelivered steel or else Steel would refuse all future business with Machinery - a relationship worth roughly $1,000,000 annually to Machinery. Machinery sued in West Virginia state court alleging Steel's threat constituted extortionate economic duress, and the trial court certified questions to the state's highest court.
Whether the expectancy of a future business relationship is a legal right on which a plaintiff may base a claim of economic duress.