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R. G. Varner Steel Products, Inc. v. Puterbaugh

Citations: 233 Ark. 953; 349 S.W.2d 805; 1961 Ark. LEXIS 510Docket: 5-2439

Court: Supreme Court of Arkansas; October 9, 1961; Arkansas; State Supreme Court

Narrative Opinion Summary

In a legal dispute between Varner Steel Products Company, Inc. and Billy Puterbaugh, operating as Puterbaugh Lumber and Supply Company, the central issue was the enforceability of a commission agreement. Varner claimed a balance due on an account, while Puterbaugh counterclaimed for commissions based on an alleged agreement. The jury ruled in favor of Puterbaugh, awarding him a commission amount. However, Varner appealed, arguing that the jury should have been instructed to disregard any pre-existing agreements due to a written Dealer’s Agreement executed on May 27, 1959, which superseded prior informal arrangements. The appellate court found that the trial court erred in not providing this instruction, reversing the judgment and remanding the case. The appellate decision hinged on the necessity of proving any subsequent contractual agreement by Puterbaugh, which the jury could consider due to the existence of some supporting testimony, despite its weakness. This case underscores the importance of clear contractual terms and the procedural requirement to instruct juries correctly on the law applicable to the facts presented.

Legal Issues Addressed

Enforceability of Written Contracts

Application: The written Dealer's Agreement executed on May 27, 1959, explicitly superseded all prior agreements between Varner and Puterbaugh, negating any claims based on earlier oral agreements.

Reasoning: The written contract explicitly stated that it supersedes any prior agreements, preventing Puterbaugh from relying on any previous contract with Varner made before May 27, 1959.

Jury's Role in Determining Contractual Obligation

Application: The jury was entitled to consider Puterbaugh’s claim of a subsequent agreement for commission despite weak evidence, as it involved factual determinations regarding the nature and existence of the contractual obligation.

Reasoning: Although evidence for a subsequent contract was not strong, it was deemed sufficient for the jury’s consideration, particularly as Puterbaugh testified to a 5% commission agreement following the written contract.

Reversal and Remand Due to Instruction Error

Application: The trial court's refusal to give Varner's Instruction No. 6, which required proof of a valid agreement postdating the written contract, was a reversible error, leading to the case being remanded.

Reasoning: The refusal to give Varner’s Instruction No. 6 led to the reversal of the judgment and remand of the case.