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Lake River Corporation, Plaintiff-Appellee-Cross-Appellant v. Carborundum Company, Defendant-Appellant-Cross-Appellee

Court of Appeals for the Seventh Circuit (1985) | 769 F.2d 1284; 1985 U.S. App. LEXIS 21908

4 min read

TL;DR: A contract's minimum-quantity guarantee was deemed an unenforceable penalty, not valid liquidated damages, because it awarded the full contract price for undelivered goods without deducting saved costs. An asserted lien was also invalidated.

Legal Significance: This case illustrates the stringent test for liquidated damages under Illinois law, emphasizing that clauses grossly disproportionate to actual or probable damages, particularly by ignoring saved costs, constitute unenforceable penalties.

The life of the law has not been logic; it has been experience.

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