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Simmons Foods, Inc. v. Hill's Pet Nutrition, Inc.

United States Court of Appeals, Eighth Circuit

270 F.3d 723, 45 UCC Rep. Serv. 2d 1055 (2001)

Relevant factsFree

After Simmons (plaintiff) invested in equipment to supply specialized poultry meal to HPN (defendant), a 1997 fax listing 1998 terms became the basis for Simmons's claim of a three-year agreement, but the actual signed contracts specified only one-year durations and quantities; when the relationship ended after a 1999 pricing dispute, Simmons sued for breach of the alleged three-year deal and for promissory estoppel based on its equipment investment made in reliance on an oral long-term promise, and the district court granted HPN summary judgment on both claims.

IssueFree

Whether, under the UCC, a party may introduce parol evidence to contradict a term explicitly specified in a written contract for the sale of goods.

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