Thursday, December 10, 2015

Section 2-201(2): Reply or Cry


Once it has been determined that Article 2 governs, the next series of questions concerns the parties’ agreement, and possible contract resulting from that agreement:
What are the terms of the agreement between the parties?
How does the UCC impact the parties’ agreement?
How do supplemental general principles of law impact the parties’ agreement?
This basic analysis is called for by the definitions of contract and agreement, both of which were discussed extensively in earlier posts. By way of quick review, contract is defined under Section 1-201(b)(12) as ‘the total legal obligation that results from the parties agreement as determined by the Uniform Commercial Code as supplemented by any other applicable laws.  It is quickly apparent that in order to know what the contract is between the parties, it is necessary to determine the contents of the parties’ agreement, for the contract is the legal result of their agreement.
‘Agreement’ is defined as the bargain of the parties in fact, as found in their language or inferred from other circumstances, including course of performance, course of dealing, or usage of trade as provided in Section 1-303.’ The importance of course of performance, course of dealing and usage of trade in this analysis is critical, and has been discussed several times in earlier posts.  The essence of their importance lies in the fact that each of these components can supply terms to a contract that may never have been discussed or negotiated.
Once all of the terms are understood, the second element of the definition of contract kicks in: What is the impact of the Uniform  Commercial Code on the parties’ agreement?  The first question is whether the proposed transaction is within the purview of the Uniform Commercial Code. This is the scope question discussed in the last post. The second question which must be asked in this context is: Is the contract enforceable?  That analysis begins with the Article 2 Statute of Frauds contained in Section 2-201.  The basic rule is stated in Section 2-201(1):
Except as otherwise provided in this section a contract for the sale of goods for the price of $500 or more is not enforceable by way of action or defense unless there is some writing sufficient to indicate that a contract for sale has been made between the parties and signed by the party against whom enforcement is sought or by his authorized agent or broker. A writing is not insufficient because it omits or incorrectly states a term agreed upon but the contract is not enforceable under this paragraph beyond the quantity of goods shown in such writing.
Section 2-201(1) is clear and very straightforward.  If the contract has a value of $500 or more, there must be a writing which sufficiently indicates such a contract, and which is signed by the party ‘against whom enforcement is sought.’  Therefore, a purported seller of goods who seeks to hold a particular person liable as a buyer, must have a writing signed by the buyer or by his authorized agent or broker.  Similarly, a buyer seeking to hold a person liable as a seller must have a writing signed by the seller.
            The basic rule of Section 2-201(1) has several exceptions.  The Reply Doctrine of Section 2-201(2) has particular significance for two primary reasons.  First, the downside for not understanding and following the rule of Section 2-201(2) can be devastating to a business.  Second, most businesses are unaware of Section 2-201(2) and hence are in a state of potential major liability.  Section 2-201(2) states as follows:
Between merchants if within a reasonable time a writing in confirmation of the contract and sufficient against the sender is received and the party receiving it has reason to know its contents, it satisfies the requirements of subsection (1) against such party unless written notice of objection to its contents is given within 10 days after it is received.
The best way to illustrate the impact is by way of a simple hypothetical:
Assume that you are a manufacturer of tables that you sell at the wholesale level to retailers for $1,000.
You receive a call from a potential buyer who wants to buy 1000 tables for a motel chain and, given the large order, offers you $650.00 for the tables.
You advise buyer that you have no interest in selling your tables for $650.00 and unless he is willing to pay the full $1,000 you have no interest in further discussions with him.
Several days later, you receive the following email:
            Dear Seller:
Pursuant to our discussion of December 4, 2015 I confirm our contract and agree to purchase 1000 tables from you for $650.00 per table.  I appreciate your recognition of this large order through your discounted price.
Sincerely,
Buyer
You read the email and think to yourself ‘This guy is crazy’ so you delete the email, not knowing that your transaction falls within Section 2-201(2).          
Both parties are merchants, so the first prerequisite of Section 2-201(2) is met.  The writing confirms the contract and is ‘sufficient against the sender’—i.e.—signed by the sender—in this case, the alleged buyer.  Hence the second prerequisite is met.  The third requirement will also be met—i.e.—the person receiving it ‘has reason to know of its contents’ since it was sent to his account via email. 
At this point, unless the seller gives written notice of objection to its contents,  within 10 days of receipt, buyer will have been deemed to have satisfied the requirements of the Statute of Frauds.  This may seem to be a harsh result, but the Code is expressing support for a basic business protocol— answer your business communications in a timely manner.  That is reasonable commercial behavior. If you don’t answer your business communications in a timely manner, and one of those communications confirms a nonexistent contract, you are exposed in a major way.    
This does not mean that the buyer will win in a lawsuit for the 1000 tables at $650.00 per table. However it does mean that one of two things will happen—you will either incur the expense of litigation proving your case, or you will settle.  Both of these can be avoided with a simple one sentence reply denying the existence of the contract.

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