Law School Case Brief
Bolin Farms v. Am. Cotton Shippers Asso. - 370 F. Supp. 1353 (W.D. La. 1974)
Agreements legally entered into have the effect of laws on those who have formed them. They cannot be revoked, unless by mutual consent of the parties, or for causes acknowledged by law. They must be performed with good faith.
Plaintiff cotton farmers entered into forward sales contracts with defendant purchasers, by which they agreed to sell their cotton to the purchasers at a fixed price. After the price of cotton doubled, the farmers sought a declaration that the contracts were null and void so that they could obtain a better price for the cotton. The parties filed summary judgment motions.
Were the forward sales contracts to sell and purchase cotton at a fixed price held to be valid and enforceable, thus entitling defendant purchasers to specific performance by plaintiff farmers?
The United States District Court entered summary judgment in favor of defendant cotton purchasers. The Court held that whatever caused the price of cotton to rise after the contracts were executed had no relevancy to the contracts' validity. The Court held that the contracts were valid and enforceable, given that the parties were willing to sell and buy, were adults, were experienced in dealing with forward sales contracts in an open and competitive market. The Court held that the purchasers were entitled to specific performance under Louisiana law. Accordingly, the Court ordered plaintiff farmers to deliver the cotton in accordance with the contracts.
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