Summary
This Eighth Circuit opinion affirms a district court's judgment in favor of K7 Design Group against Walmart, Inc., doing business as Sam’s Club, following a jury verdict on breach of contract claims related to the sale of hand sanitizer during the COVID-19 pandemic. The appellate court addressed whether email communications between the parties constituted binding orders under Arkansas's Uniform Commercial Code despite a broader Supplier Agreement, and rejected the appellant's challenges to the denial of its motions for judgment as a matter of law and a new trial. The court held that sufficient evidence supported the jury's finding that Sam’s Club committed to purchasing specific quantities of hand sanitizer and failed to collect or pay for them.
Topics
Practice areas
Questions Presented
- Whether the evidence was sufficient to support a jury finding that a contract for the sale of goods existed and that Sam’s Club breached that contract, thereby precluding judgment as a matter of law.
- Whether the district court abused its discretion in denying Sam’s Club’s motion for a new trial and in the jury instructions given.
Holdings
- The court held that a reasonable jury could find that the parties’ email communications constituted enforceable orders under the Supplier Agreement, establishing a contract for the sale of goods and a breach, so the district court was correct in denying judgment as a matter of law.
- The court held that the district court did not abuse its discretion; the jury instructions on the UCC and contract law fairly and adequately submitted the issues to the jury, and the evidence allowed reasonable jurors to reach the verdict.
Key quotations
“We review the district court’s denial of a motion for judgment as a matter of law de novo and consider the evidence in the light most favorable to the jury’s verdict.” (at 8)
“The jury could have believed either party’s witnesses and drawn all reasonable inferences from their testimony to conclude Sam’s Club had not canceled its orders of hand sanitizer pursuant to the Supplier Agreement.” (at 10)
Factual background
K7 Design Group supplied hand sanitizer to Sam’s Club during the COVID‑19 pandemic. The parties exchanged numerous emails confirming quantities, prices, and delivery schedules, and K7 delivered millions of units to its warehouses for Sam’s Club to collect. Sam’s Club failed to pick up and pay for a large portion of the product, leading K7 to sue for breach of contract and promissory estoppel.
Procedural history
The district court tried the case, a jury found in favor of K7 on breach of contract and awarded damages. Sam’s Club moved for judgment as a matter of law and for a new trial; the district court denied both motions. The parties appealed.