St. Ansgar Mills, Inc. v. Streit
Supreme Court of Iowa
613 N.W.2d 289 (2000)
St. Ansgar (plaintiff) regularly sold grain to farmer Streit (defendant) by phone quote followed by written confirmation signed during Streit's customary monthly store visit; after Streit accepted a July 1, 1996 quote by phone, St. Ansgar prepared a written confirmation, but Streit didn't visit the store in July as usual and didn't receive the confirmation until August 10, after corn prices had fallen, at which point he refused delivery and bought corn elsewhere at the lower market price. St. Ansgar sued for breach, and the district court granted Streit summary judgment, finding the confirmation wasn't received within a reasonable time.
Whether a court may determine as a matter of law that written confirmation of an oral agreement between merchants was received within a reasonable time under the UCC's Statute of Frauds exception.