Minneapolis & St. Louis Railway Co. v. Columbus Rolling-Mill Co.
United States Supreme Court
119 U.S. 149 (1886)
Minneapolis & St. Louis Railway Co. (plaintiff) asked Columbus Rolling-Mill Co. (defendant) for a price quote on 2,000 to 5,000 tons of iron rails, and Columbus offered to sell within that range at $54.00 per ton. Minneapolis then telegraphed an order for only 1,200 tons at that price, which Columbus rejected; Minneapolis then telegraphed a new order for 2,000 tons at $54.00 per ton, to which Columbus never responded, and after repeated inquiries, Columbus ultimately denied any contract existed between the parties. Minneapolis sued for breach of contract, and the trial court ruled for Columbus.
Whether, when an offer is made, the acceptance must be based upon the exact terms contained in the offer.