Republic Steel v. Protrade Steel Co., Ltd.

2018 Ohio 469
CourtOhio Court of Appeals
DecidedFebruary 5, 2018
Docket2017CA00048
StatusPublished
Cited by2 cases

This text of 2018 Ohio 469 (Republic Steel v. Protrade Steel Co., Ltd.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Republic Steel v. Protrade Steel Co., Ltd., 2018 Ohio 469 (Ohio Ct. App. 2018).

Opinion

[Cite as Republic Steel v. Protrade Steel Co., Ltd., 2018-Ohio-469.]

COURT OF APPEALS STARK COUNTY, OHIO FIFTH APPELLATE DISTRICT

REPUBLIC STEEL : JUDGES: : Hon. W. Scott Gwin, P.J. Plaintiff-Appellee : Hon. William B. Hoffman, J. : Hon. Earle E. Wise, Jr., J. -vs- : : PROTRADE STEEL CO., LTD. : Case No. 2017CA00048 : Defendant-Appellant : OPINION

CHARACTER OF PROCEEDING: Appeal from the Court of Common Pleas, Case No. 2015CV01186

JUDGMENT: Affirmed

DATE OF JUDGMENT: February 5, 2018

APPEARANCES:

For Plaintiff-Appellee For Defendant-Appellant

BENJAMIN C. SASSE WILLIAM H. FALIN JOHN Q. LEWIS JOHN M. MOSCARINO SETH J. LINNICK The Hanna Building PAUL L. JANOWICZ 1422 Euclid Avenue, Suite 630 950 Main Avenue, Suite 1100 Cleveland, OH 44115 Cleveland, OH 44113 Stark County, Case No. 2017CA00048 2

Wise, Earle, J.

{¶ 1} Defendant-Appellant ProTrade Steel Co., LTD (ProTrade) appeals the

February 23, 2017 judgment of the Court of Common Pleas of Stark County, Ohio

overruling Protrade’s objections to the Magistrate’s decision. Plaintiff-Appellee is

Republic Steel (Republic).

FACTS AND PROCEDURAL HISTORY

{¶ 2} Republic is a producer of steel, and ProTrade is a scrap metal broker.

Republic has been purchasing scrap steel from ProTrade since 2005. At some point

during the business relationship, Republic had difficulty making timely payments to

ProTrade, and the companies ceased doing business from 2008 to 2013. In 2013, when

the parties began doing business again, it was with the agreement that Republic would

obtain a letter of credit in favor of ProTrade. HSBC Bank (“HSBC”) issued a $5 million

letter of credit to Republic in August of 2013, which was increased to $10 million in March

of 2014.

{¶ 3} Republic purchased scrap steel from ProTrade by issuing purchase orders.

Each purchase order contained terms of payment within 45 days, listed the type and

quantity of scrap to be purchased, the unit price of the scrap, and the due date for delivery

of the scrap. Under this system, Republic issued a purchase order, ProTrade delivered

the quantity of scrap requested, and either Republic paid the amount due or it was

submitted to HSBC for payment against the letter of credit.

{¶ 4} During the second half of 2014, Republic’s payments became consistently

late. In October 2014 a conference call took place between representatives of Republic

and ProTrade. Republic acknowledged financial difficulty and requested leniency with the Stark County, Case No. 2017CA00048 3

45-day payment terms. According to ProTrade, all parties agreed that ProTrade would

continue to ship scrap even though Republic was behind on payments, but only up to the

$10 million available on the letter of credit. As Republic paid down the balance, ProTrade

would fulfill outstanding scrap orders in an amount equivalent to that paid down by

Republic.

{¶ 5} Following this discussion, Republic continued to place new purchase orders

with ProTrade and ProTrade continued to provide scrap as past-due payments were

submitted by Republic. The dispute here arose when Republic cancelled five purchase

orders between October 2, 2014 and January 12, 2015 because ProTrade failed to

complete delivery of the scrap by the due dates specified in the purchase orders.

{¶ 6} According to Republic, even though it was behind on payments for previous

orders, ProTrade was nonetheless contractually obligated to deliver each order by the

delivery date specified in each purchase order. According to ProTrade, the delivery dates

specified in the purchase orders were ignored due to the parties’ alternative agreement.

{¶ 7} During this same time, ProTrade contacted Republic regarding past due

balances. Republic was warned it needed to catch up on payments or ProTrade would

cancel outstanding purchase orders. Republic responded it had not agreed that the orders

were cancelled.

{¶ 8} In February 2015, however, Republic sent an email to ProTrade advising

that Republic was cancelling 13 outstanding purchase orders, including the five that

became the basis of this litigation. ProTrade had not delivered the scrap for any of those

five purchase orders. Because delivery had not taken place by the date on the invoice,

Republic maintained it had a right to cancel. ProTrade on the other hand, disagreed. Stark County, Case No. 2017CA00048 4

{¶ 9} Republic cancelled these orders at a time when the market price of scrap

fell, meaning if the scrap had been delivered, Republic would have paid more for the

scrap than it was worth. On February 13, 2015, ProTrade claimed a market loss due to

Republic's cancellation of orders for the undelivered scrap. ProTrade issued a

“commercial invoice” to Republic for $1,284,362 in market loss. When Republic refused

to pay, ProTrade submitted the market loss invoice to HSBC and HSBC paid the invoice

from Republic’s letter of credit.

{¶ 10} In June, 2015, Republic filed a breach of contract complaint against

ProTrade to recover the $1,284,362.

{¶ 11} In September 2016, upon written agreement of the parties, the matter went

before a magistrate for a jury trial. The issues before the jury were whether Republic had

the right to cancel overdue purchase orders and whether the due dates in the purchase

orders had been modified or waived. The parties stipulated that the five purchase orders

were written contracts.

{¶ 12} The trial began on September 19, 2016. At trial, the videotaped deposition

of David Spector, Republic’s scrap industry expert, was played for the jury as Spector

was unavailable at the time of trial. Spector explained that the scrap steel market is a 30-

day market, meaning the price of steel scrap fluctuates every 30 days, sometimes

dramatically. Negotiations between suppliers and mills therefore take place monthly.

Spector further explained that because of fluctuations in the cost of scrap, it is common

industry practice for steel mills to cancel overdue purchase orders when the price of scrap

drops. Spector further stated he was personally unaware of a circumstance where a Stark County, Case No. 2017CA00048 5

scrap dealer had invoiced and pursued a mill for market losses after cancellation of an

overdue order of unshipped scrap.

{¶ 13} On cross examination, ProTrade first established that Spector was not

personally aware of an industry practice where a scrap dealer has the right to recover

market losses for unshipped scrap upon a mill’s cancellation. ProTrade then sought to

introduce pleadings from a U.S. District Court for the Northern District of Ohio case

captioned 1795906 Ontario Inc., dba GTA Industrial Metals v. PSC Metals Inc., (the GTA

pleadings). The matter contained a counterclaim for market losses filed by Spector's

former employer PSC Metals, Inc. PSC's counterclaim was based on GTA's cancellation

of purchase orders. Spector had been PSC’s president the year the GTA pleadings were

filed, but he had stepped down the month the counterclaim was filed. Spector testified

had no knowledge or memory of the GTA litigation, nor any recollection of doing business

with GTA, and ProTrade presented no evidence to demonstrate that Spector had any role

in the GTA litigation. At trial, the magistrate excluded this portion of Spector’s testimony.

{¶ 14} On September 23, 2016, the jury returned a unanimous verdict in favor of

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Republic Steel v. Protrade Steel Co., Ltd.
2018 Ohio 469 (Ohio Court of Appeals, 2018)

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