New York Central Iron Works Co. v. United States Radiator Co.
Court of Appeals of New York
66 N.E. 967 (1903)
Relevant factsFree
United States Radiator Co. (defendant) agreed to supply New York Central Iron Works Co. (plaintiff) with all the radiators it needed for a year at a set price. After delivering 48,000 feet of radiation — more than Iron Works had ever previously ordered in a year — Radiator refused to fill further orders that would have pushed the yearly total above 100,000 feet, and Iron Works sued for breach. The trial court ruled for Iron Works, and Radiator appealed.
IssueFree
Whether a court may imply an unstated quantity limit into a requirements contract when the buyer's orders increase sharply due to a rising market, absent proof that the buyer acted in bad faith.