Mottram v. United States
Headline: Auction buyer’s claim for massive steam packing denied as Court affirms dismissal; catalogue error and buyer’s inspection mean the United States need not deliver the mistaken quantity.
Holding: The Court held the buyer cannot recover because the catalogue overstated quantity, the buyer had the chance to inspect and was warned against errors, and the United States was not required to deliver the mistaken amount.
- Buyers cannot rely on catalogue quantities when error is obvious and they inspected goods.
- Sellers who disclaim warranties in sale notices avoid liability for catalogue mistakes.
- Government need not deliver quantities never held at depot despite a buyer’s winning bid.
Summary
Background
A private buyer attended an auction of surplus U.S. Army supplies at the United States Engineers' Depot in Slough, England. The sale was held under authority of Congress and run by agents who issued a catalogue listing items and quantities. Due to a transcription error, quantities of Garlock steam packing were listed one hundred times larger than the actual stock. The buyer inspected the depot, saw the packing, received the catalogue, bid on the lots as listed, paid, and later tried to demand delivery of the enormous quantity shown in the catalogue.
Reasoning
The Court addressed whether the buyer could recover damages for failure to deliver the catalogue amount. The catalogue expressly warned sales were subject to errors and made without warranty, and the auctioneer had said he would not guarantee quantities. The buyer had multiple chances to inspect the goods and the overstatement was obvious from the actual stock. The Court found the buyer was charged with knowledge of the true situation and could not claim more than the United States actually held. Because there was no showing the seller refused to deliver whatever quantity existed, the buyer could not recover for the mistaken, nonexistent amount.
Real world impact
The ruling leaves the buyer without recovery and affirms that obvious catalogue mistakes and explicit disclaimers can protect sellers, including the government, from obligations to deliver nonexistent quantities. Buyers at similar surplus sales should rely on personal inspection and beware catalogue descriptions that disavow warranties.
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