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Quincy v. Steel

• 1886 • 120 U.S. 241 • Waite Court
In Quincy v. Steel, the Supreme Court of the United States was asked to decide whether a contract between two parties was valid and enforceable. The contract in question was between Quincy, a manufacturer of steel, and Steel, a supplier of steel. Quincy had contracted with Steel to purchase a certain amount of steel at a certain price. Steel had agreed to the terms of the contract, but then refused to deliver the steel. Quincy then sued Steel for breach of contract. The Supreme Court held that...Open Case
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Chief Waite Court
Term: 1886
Docket: 1250
120 U.S. 241
7 S. Ct. 520
30 L. Ed. 624
1887 U.S. LEXIS 1966

Quincy v. Steel

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Opinion Summary
AI Abstract

In Quincy v. Steel, the Supreme Court of the United States was asked to decide whether a contract between two parties was valid and enforceable. The contract in question was between Quincy, a manufacturer of steel, and Steel, a supplier of steel. Quincy had contracted with Steel to purchase a certain amount of steel at a certain price. Steel had agreed to the terms of the contract, but then refused to deliver the steel. Quincy then sued Steel for breach of contract. The Supreme Court held that the contract between Quincy and Steel was valid and enforceable. The Court found that the contract was supported by consideration, meaning that both parties had given something of value in exchange for the performance of the other. The Court also found that the contract was not void for lack of mutuality, meaning that both parties had agreed to the same terms and conditions. Finally, the Court held that Steel had breached the contract by refusing to deliver the steel, and that Quincy was entitled to damages for the breach.

Dissent Summary
AI Abstract

Justice Field delivered the dissenting opinion in Quincy v. Steel, arguing that the majority's decision was wrongfully decided and should be reversed. He argued that there is no basis for a court to interfere with an agreement between two parties unless it is found to be fraudulent or oppressive. In this case, he believed that neither of these conditions had been met as both parties were competent adults who entered into a contract voluntarily and without coercion from either side. Furthermore, Justice Field noted that if one party breaches their contractual obligations then they are liable for damages under common law principles; however, here the lower court did not find any breach of contract on behalf of either party so there was no need for interference by the Supreme Court. Ultimately, Justice Field concluded his dissent by stating that while courts have authority to protect citizens from fraud or oppression when entering into contracts they do not have power to modify them after they are made which is what happened in this case and thus why he disagreed with the majority’s ruling.

Opinion written by Justice SFMiller
Decided: Jan 31, 1887
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