• U.S. District Court
  • 3:10cv878
  • May 29 2014 (Date Decided)
  • Underhill, J.

Judgment as a matter of law may only be granted if: 1.) the jury’s conclusion could only have been the result of surmise and conjecture; or 2.) fair-minded individuals could not have reached a verdict against the movant. Plaintiff RBC Aircraft Products alleged that the parties entered into five-year requirement contracts (in which the defendant promised to buy exclusively from the seller), and that defendant Precise Machining and Manufacturing breached the contract in 2010. Precise Machining, which manufactures wing assembly kits for Boeing 737s, denied it breached the contract when it placed orders with a competitor in 2010 and claimed that RBC’s price quote was only a solicitation for an offer. A jury concluded that Precise Machining breached a contract and returned a $2.9 million verdict in favor of RBC. Precise Machining moved for judgment as a matter of law and argued that the evidence failed to support a conclusion that the parties entered into a five-year requirements contract. RBC’s price quote included information about the product, delivery method, quantity, minimum order and price. It included the language, “If [an] order is placed by Precise, RBC order terms & conditions will apply.” It added, “All orders and contracts solicited by any representative of this company are subject to approval by the company at its Home Office.” RBC executives testified that they approved the price quote before it was sent. The jury reasonably could have found that RBC’s quote constituted an offer and that Precise Machining’s purchase order constituted acceptance. The jury awarded damages for breach of a five-year requirements contract. .The court found that Precise did not intend to bind itself to a five-year requirements contract. RBC’s marketing manager, Brian Christiano, conceded that it was clear in May 2009 that Precise Machining would not enter a long-term contract. The jury wrongly concluded that Precise Machining breached the five-year requirements contract. A reasonable jury could not have found an essential element of RBC’s claim. The District Court granted Precise Machining’s Rule 50(b) motion for judgment as a matter of law and vacated the judgment in favor of RBC.

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