Northern Indiana Public Service Co. v. Carbon County Coal Co

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Brief Fact Summary.

Carbon County Coal Company (Plaintiff) had a contract with Defendant to supply coal. Defendant found a much cheaper supply of coal and sought a declaratory judgment to be released from the contract. Plaintiff counter sued for a preliminary injunction and specific performance.

Synopsis of Rule of Law.

Specific performance is not appropriate when there is and adequate remedy at law and declaring specific performance would further injure the defendant and society as a whole.

Facts.

Plaintiff had a contract to supply defendant with coal. Defendant found a cheaper supplier of coal and sought a declaratory judgment to be released from the contract. Plaintiff counter sued for a preliminary injunction and specific performance. After a jury trial, Plaintiff received an award of $181 million dollars.

Issue.

Should Plaintiff get specific performance?

Held.

No.
The award at law is adequate to make Plaintiff whole.
Plaintiff argues that the award will not help the workers who lost their jobs or the business that went under because Plaintiff’s mine closed. The court indicated that they were not parties to the lawsuit.
Ordering specific performance and forcing Defendant to buy coal that Defendant does not need for a price that is higher than fair market value of coal, is contrary to public policy.

Discussion.

Beyond the usual reason for denying specific performance, the court finds public policy reasons for not granting specific performance. Still, the case turns on the fact that money damages were enough to make the Plaintiff whole.