Security Stove & Manufacturing Co. v. American Railway Express Co. — Quick Summary

Security Stove & Manufacturing Co. v. American Railway Express Co.

144 S.W.2d 830 (Mo. App. 1932)

In Brief

The case of Security Stove & Manufacturing Co. v.

Key Issue

Can a party recover consequential damages in a breach of contract when the damages were foreseeable and directly resulted from the breach?

The Rule

Consequential damages can be awarded in a breach of contract case if the damages were reasonably foreseeable and can be directly attributed to the breach at the time the contract was made.

Bottom Line

The court held that Security Stove was entitled to recover consequential damages because American Railway Express had known the importance and urgency of the timely delivery; thus, the losses resulting from the breach were foreseeable.

Why It Matters

This case underscores the critical intersection between foreseeability and recoverability of consequential damages in contract law. It serves as a cornerstone for understanding how courts evaluate the parties' awareness of potential losses at the time of contract formation. Law students can learn the importance of ensuring that all relevant information is communicated clearly in contract negotiations, especially when specific performance is crucial.

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