Young v. Frank's Nursery & Crafts, Inc.

Young (plaintiff), a pine-bough supplier, geared up to fill a 360-ton order from Frank's Nursery (defendant), securing cutting rights, repairing equipment, and building new bundling tools. Frank's then reduced its order to 70 tons before the cutting season; Young sought other buyers, but the market had already been claimed by other sellers, so he cut only enough to fill Frank's reduced order and sued for lost profits on the difference. Frank's conceded the breach but argued Young's decision not to cut the original volume was commercially unreasonable, and the court of appeals agreed the trial court wrongly placed that burden on Frank's rather than Young.

Whether, under the Uniform Commercial Code, a buyer who anticipatorily breaches its contract with a seller has the burden of showing that the seller's decision to cease production was unreasonable.