Continental Forest Products, Inc. v. Chandler Supply Co.

518 P.2d 1201 · Idaho Supreme Court · 1974

Facts

Chandler ordered plywood from North America Millwork (NAM), with whom it had a pre-existing trade debt. An NAM employee diverted Chandler's orders to Continental Forest Products, which then shipped the plywood to Chandler. Chandler received and accepted the plywood but attempted to pay NAM, deducting its trade debt, which NAM rejected, leading Continental to sue Chandler for the full price.

Issue

Did a quasi-contract exist between Continental and Chandler, obligating Chandler to pay for the plywood, and if so, should Continental's recovery be reduced by Chandler's pre-existing trade debt with North America Millwork?

Holding

Yes, a quasi-contract existed, obligating Chandler to pay Continental for the plywood. However, Continental's recovery was reduced by the amount of Chandler's trade debt with North America Millwork, as it would be unjust for Chandler to lose that set-off given Continental's role in the transaction.

Rule

The measure of recovery in a quasi-contractual action is the amount of enrichment that, as between the two parties, it would be unjust for one party to retain, not necessarily the full value received, especially when the plaintiff contributed to the circumstances.

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Case brief last reviewed 2026-03-19. Prepared by CaseReader from the published opinion.