In a move that could impact tens of thousands of workers and 30% of U.S. goods, there may be a freight rail stoppage starting Friday, September 14, 2022, if rail operators and unions fail to reach a deal by 12:01 a.m. ET on Friday.  Due to this potential lack of staff, as of Tuesday, September 13, some rail operators even stopped accepting certain freight (such as hazardous materials), because there may not be anyone available to manage and keep it safe.  While the media skews towards doom and gloom—predicting a massive of collapse of the supply chain—experts and commentators do expect that halted freight shipments will disrupt the already strained U.S. supply chain, including automotive and other manufacturing companies that operate on a just-in-time sole source basis.

Since the onset of COVID, the question that has come up more times than I can count is upon us once again: What can my company do to protect itself and enforce contract rights when supply is disrupted, both downstream and upstream?  Can we compel suppliers to deliver under the contract?  Can we issue a force majeure notice to our customers to avoid liability for non-delivery?

The solution depends on the facts of each matter, and, in the United States, will be answered by the applicable contract language and law.  If your company receives a force majeure letter, below are some steps to consider.  While not all of these options are available under the contract or law at issue, they may put the company in the best position to secure supply, to preserve claims against a supplier, and to protect against a larger customer claim later.

  1. Review what qualifies as force majeure under the contract language (don’t assume)
  2. Respond quickly to a force majeure notice
  3. Ask for specific information regarding the non-delivery
  4. Demand compliance with the contract
  5. Assert refusal to modify the contract
  6. Evaluate any allocation proposal and assert objections if appropriate
  7. Evaluate whether the supplier can manufacture and ship the goods using alternative sources
  8. Consider whether seeking a preliminary order requiring supply is a legal option under your contract
  9. Reserve all rights in communications
  10. Consider sending notice upstream (declare force majeure to your customers)

While there are legal pros and cons applicable to each of the options above, if you believe your company will be impacted as of Friday (and early next week if a strike ensues), now is the time to start evaluating legal options.

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Photo of Laura C. Baucus Laura C. Baucus

Laura Baucus is a results-oriented litigator and business attorney with experience delivering consistent results to clients in the automotive, aerospace, manufacturing and financial services industries. Ms. Baucus has worked both as outside counsel and as seconded in-house counsel. She is the Director of…

Laura Baucus is a results-oriented litigator and business attorney with experience delivering consistent results to clients in the automotive, aerospace, manufacturing and financial services industries. Ms. Baucus has worked both as outside counsel and as seconded in-house counsel. She is the Director of Dykema’s 140+ attorney Automotive Industry Group, the immediate past Leader of the firm’s Financial Services Litigation Practice, a Leader in Dykema’s COVID-19 Task-Force, the originator of the firm’s Supply Chain Group, the Manager of a firm OEM client-service team, and the immediate past Manager of the firm’s largest Michigan office.

Ms. Baucus regularly counsels clients on force majeure and related contract performance options. Her litigation practice focuses on procurement and supply chain, recalls, warranty and cost recovery, contract termination, tooling recovery, Uniform Commercial Code issues, and financial services.  Her contract practice includes negotiating and drafting supply contracts and other commercial agreements for automotive and other manufacturing companies, including terms and conditions. Ms. Baucus also manages national portfolios of lawsuits for some of the nation’s largest residential mortgage servicers.