Porto Rico Sugar Co. v. Lorenzo

Background

A grower who raised sugar cane on plantations entered written grinding contracts covering certain zafras (grinding seasons) through 1912 with a contractor to grind his crop. The grower sued after the contractor failed to grind much of the cane during the expected January–June 1908 season, instead grinding large parts in late June and through July, and also failed at times to provide enough cars and men. At trial the jury awarded $15,000 and the defendant appealed.

Reasoning

The key question was whether a written contract that does not name exact dates can be enforced as requiring seasonal performance. The Court said a contract to grind sugar cane naturally refers to the industry’s grinding season, and industry (oral) evidence may be used to show when that season is in a particular place. The Court rejected the idea that equipment breakdowns excused an absolute promise to perform. Reading the contract with knowledge of the business, the Court found the delay and failures left the contractor responsible and affirmed the judgment.

Real world impact

The decision means that in the sugar business, written milling agreements that do not list calendar dates can still require work during the ordinary grinding season, proven by local industry practice. Mill operators who delay grinding or fail to supply cars and workers can be held liable for crop damage. The judgment affirms the trial result and requires contractors to bear losses caused by late or incomplete performance.