Fairmount Glass Works v. Crunden-Martin Woodenware Co. – Case Brief Summary
Summary of Fairmount Glass Works v. Crunden-Martin Woodenware Co., 106 Ky. 659, 51 S.W. 196 (1899).
Facts
Crunden-Martin (P) requested a quote from Fairmount Glass Works (D) for ten car loads of mason jars. Fairmount responded by telegram with prices for different sizes of jars and shipping and payment terms “for immediate acceptance.” Crunden telegraphed an order for ten carloads the next day, indicating that specifications regarding size and quality would be forwarded by mail. Fairmount replied to Crunden’s telegram the same day indicating that the requested goods were sold out and the order could not be filled. Fairmount received the specifications for the order the next day.
Crunden brought suit for breach of contract, contending that Fairmount’s telegram containing price quotations constituted an offer and a binding contract was formed when Crunden accepted. Fairmount contended that it provided a price quotation only and that it was free to decline Crunden’s order. The trial court entered judgment for Crunden and Fairmount appealed.
Issue
- How must the court determine whether a communication constitutes an offer?
Holding and Rule
- In order to determine whether a communication constitutes an offer, the court must determine the contractual intent of the parties and the true meaning of the correspondence must be determined by reading it as a whole.
The expression “for immediate acceptance” in Fairmount’s telegram, taken in context with Crunden’s request for a price quotation, indicates that it was meant to be an offer which formed a binding contract when accepted. Fairmount’s telegram was not merely a quotation of prices. It was a definite offer to sell on the terms indicated and could not be withdrawn after the terms had been accepted.
Disposition
Judgment for plaintiff Crunden affirmed.
See Harvey v. Facey for a contract law case brief in which the court held that a mere statement of the minimum selling price of real estate is an invitation to trade and not an offer to sell.