Plateq Corp of North Haven v. Machlett Labs., Inc.
189 Conn. 433, 456 A.2d 786 (Conn. 1983)

  • Machlett ordered some special radiation-proof steel tanks from Plateq.  The contract stipulated that the tanks would be tested after installation.
    • Plateq had never made radiation-proof tanks before and Machlett had never designed them before.
  • Plateq encountered some difficulties and delays with performance.  Machlett’s engineer inspected the finished product at Plateq’s facility, noted a few minor deficiencies, but said that Machlett would pick up the tanks the next day.  However, instead, they canceled the contract (without specifying why).  Plateq sued.
  • The Trial Court found for Plateq.
    • The Trial Court found that the goods were substantially complete.
    • The Court found that Machlett had accepted the goods in accordance with UCC §2-606(1)(a) by saying they would pick the tanks up.
    • The Court found that Machlett had not made an effective rejection under UCC §2-606(1)(b).
      • Machlett needed to be very specific about what the defect was, in order to give Plateq an opportunity to make a conforming tender under UCC §2-508(2).
    • The Trial Court found that under UCC §2-608, once acceptance had occurred, Machlett could only revoke acceptance by showing substantial impairment of the goods’ value.
  • The Appellate Court affirmed.
    • Machlett unsuccessfully argued that their engineer’s final examination of the goods showed that the tanks were so incomplete and unsatisfactory that they were rightfully entitled to conclude that Plateq would never make a conforming tender.