Williams v. Medalist Golf, Inc., No. 18-1652 (8th Cir. 2018)
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The Eighth Circuit affirmed the district court's grant of summary judgment for Medalist in an action seeking damages for breach of contract and promissory estoppel. Plaintiff operates Cane Creek, which supplies, grows, and delivers sod. Medalist specializes in building high-end golf courses. The parties' dispute stemmed from a Grass Supplier Agreement to reserve grasses for a set price.
The court held that Medalist was entitled to summary judgment on the breach of contract claim because plaintiff could not show that Medalist wrongfully rejected the sod. The court also held that a reasonable jury could find that an enforceable requirements contract existed in this case, which could bar plaintiff from recovery under a theory of promissory estoppel. Even if a promissory estoppel claim were available, the court held that this was not the extreme case that would entitle plaintiff to such extraordinary relief.
Court Description: Kelly, Author, with Wollman and Erickson, Circuit Judges] Civil case - Contracts. The district court did not err in concluding the parties' agreement was a valid requirements contract; plaintiff could not, however, show that defendant wrongfully rejected the sod on the ground it did not conform to the parties' agreement that plaintiff would provide sod which would satisfy the quality standards for defendant's Gary Player-designed golf course; since there was an enforceable requirements contract, plaintiff could not recover under a theory of promissory estoppel.
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