In the case of Keystone Bridge Company v. Phoenix Iron Company, the Supreme Court of the United States was asked to determine whether a contract between the two companies was valid. The Keystone Bridge Company had contracted with the Phoenix Iron Company to build a bridge across the Schuylkill River in Pennsylvania. The contract specified that the bridge was to be built according to the plans and specifications of the Keystone Bridge Company. The Phoenix Iron Company began construction of the bridge, but then stopped work and refused to complete the project. The Keystone Bridge Company then sued the Phoenix Iron Company for breach of contract. The Phoenix Iron Company argued that the contract was invalid because it had not been approved by the Pennsylvania legislature, as required by state law. The Supreme Court held that the contract was valid and enforceable. The Court reasoned that the contract was not subject to the approval of the Pennsylvania legislature because it was a private contract between two private parties. The Court also noted that the contract was not contrary to public policy, and that the Keystone Bridge Company had a legitimate interest in having the bridge built according to its plans and specifications. The Court thus held that the contract between the Keystone Bridge Company and the Phoenix Iron Company was valid and enforceable, and that the Phoenix Iron Company was liable for breach of contract.

In Keystone Bridge Company v. Phoenix Iron Company, the Supreme Court was tasked with determining whether a contract between two parties for the sale of iron rails had been breached by one party when they failed to deliver on time. The majority opinion held that there had not been a breach as the delay in delivery was due to an act of God and thus outside of either party’s control. However, Justice Miller dissented from this ruling arguing that while it is true that neither party could have foreseen or prevented the storm which caused the delay, nevertheless both parties were aware at signing that such delays might occur and should be accounted for in their agreement; therefore, he argued, failure to do so meant that any resulting delays would constitute a breach of contract. He further noted that if no provision had been made then each side must bear its own losses rather than allowing one side to escape liability altogether simply because an unforeseen event occurred beyond their control.