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Keystone Steel & Wire Co. v. Price Iron & Steel Co.

Citations: 103 N.E.2d 143; 345 Ill. App. 305Docket: Gen. 10,534

Court: Appellate Court of Illinois; January 28, 1952; Illinois; State Appellate Court

Narrative Opinion Summary

In this case, a steel manufacturing company initiated legal proceedings against a supplier for failing to deliver scrap steel as per their contractual agreement. The plaintiff sought damages for the additional costs incurred due to this breach, claiming the defendant's failure resulted in damages amounting to $35,000. The defendant filed a motion to dismiss based on jurisdictional grounds, arguing that its office was located in a different county. However, the court ruled that jurisdiction was proper in Peoria County, where part of the transaction had occurred, denying the motion to dismiss or transfer. The trial proceeded without a jury, culminating in a judgment for the plaintiff, awarding $24,703.20, inclusive of interest. On appeal, the court affirmed the lower court’s decision, rejecting the defendant’s contention that jurisdiction was incorrectly determined and emphasizing that the contract was a purchase agreement rather than a brokerage arrangement. The appellate court further supported the calculation of damages based on the disparity between the contract price and the market price at the time of the breach, as well as the award of statutory interest on the damages. Consequently, the judgment was upheld, reinforcing the legal obligations under the contractual terms and Illinois law governing breach of contract and jurisdictional matters.

Legal Issues Addressed

Award of Interest on Damages

Application: The court upheld the award of interest on damages from the date of breach, aligning with statutory entitlements for ascertainable amounts under written contracts.

Reasoning: According to Section 2 of chapter 74 of Illinois Revised Statutes, creditors are entitled to 5% interest on due amounts.

Calculation of Damages for Breach of Contract

Application: Damages were calculated based on the difference between the contract price and the market price at the time of breach, consistent with statutory provisions.

Reasoning: The statute outlines that, in the absence of special circumstances, damages are calculated as the difference between the contract price and the market price at delivery time.

Contractual Obligations and Breach

Application: The court determined that the contract between the parties was a binding purchase agreement, not a brokerage agreement, thereby holding the defendant accountable for breach due to non-delivery.

Reasoning: The contract specified the sale of 500 tons of No. 1 Railroad Heavy Melting Steel at a set price, with delivery terms and conditions detailed.

Jurisdiction under Illinois Practice Act

Application: The court applied the principle that jurisdiction is valid where part of a transaction occurs, affirming jurisdiction in Peoria County as part of the transaction took place there.

Reasoning: The plaintiff countered that jurisdiction was valid under the Illinois Practice Act, as part of the transaction occurred in Peoria.