Fairmount Glass Works v. Crunden-Martin Wooden Ware Co.
106 Ky. 659 · Court of Appeals of Kentucky · 1899
Facts
The buyer inquired about the lowest price for ten car loads of jars, requesting terms and discounts. The seller responded with specific prices "for immediate acceptance" and terms. The buyer then sent a telegram accepting the offer for ten car loads as per the quotation, followed by a letter with specifications, but the seller refused to fill the order, claiming their output was sold.
Procedural history
The case was initially heard in a lower court, which rendered judgment in favor of the appellee, Crunden-Martin Wooden Ware Co. The appellant, Fairmount Glass Works, appealed this judgment, arguing it was erroneous. The appellate court reviewed the case and affirmed the lower court's judgment.
Issue
Was the seller's response to the buyer's inquiry a mere quotation of prices or a definite offer that, upon immediate acceptance, formed a binding contract?
Holding
The court held that the seller's letter constituted a definite offer to sell, which was accepted by the buyer's telegram, thereby forming a binding contract. The court affirmed the lower court's judgment in favor of the buyer.
Rule
A communication that specifies prices "for immediate acceptance" in response to an inquiry about the lowest price for a specific quantity of goods can be construed as a definite offer to sell, rather than a mere quotation of prices. An acceptance of such an offer creates a binding contract, even if minor specifications are later provided, especially if they align with trade usage and the seller's rejection was based on other grounds.
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