Goddard v. Crefield Mills

Crefield Mills, a Connecticut corporation, sued Goddard et al. for damages after defendants failed to take goods under a contract for manufacturing cotton goods. Defendants contended the contract included a clause prohibiting plaintiff from making similar goods for others, which plaintiff allegedly breached. At trial, jury found for plaintiff. On appeal, defendants alleged errors in evidentiary rulings and argued contract was void under New York law requiring foreign corporations to procure a certificate. The Circuit Court of Appeals affirmed, holding: (1) trial court properly refused belated expert testimony on reasonable time for performance; (2) cross-examination questions on defense matters were properly excluded; (3) hearsay testimony was correctly struck; (4) contract was not void under New York law—remedy merely suspended until certificate obtained.

Plaintiff sued defendants for damages after they failed to take goods under a manufacturing contract, which defendants claimed was breached due to an exclusivity clause and void under state law for lack of a foreign corporation certificate. The trial court ruled for plaintiff, properly excluding belated expert testimony, improper cross-examination, and hearsay while finding the contract enforceable with remedy merely suspended. The appellate court affirmed the judgment.

• Evidentiary rulings were proper and within trial court's discretion.
• New York statute does not void contracts by foreign corporations without certificates but suspends remedy.
• No error found in jury instructions or refusal of specific requests.

• Action brought in Circuit Court of the United States for the Southern District of New York
• Writ of error to review judgment entered upon jury verdict

• Refusal to allow witness Pope to give expert opinion on reasonable time
• Exclusion of cross-examination question to witness McColl
• Striking out part of testimony of defendant Frederick N. Goddard
• Failure to dismiss complaint based on violation of New York law