Also known as: mechanical utilities · utility
Written by attorneys — see sources below.
An objective criterion for assessing the quality or fitness of goods or performance in contracts. It applies when the subject matter involves commercial quality, operative fitness, or mechanical utility that knowledgeable persons can judge by reference to external standards rather than personal taste.
Malcolm McKinley contracted with Metro Bank to supply specialized engine components for its fleet vehicles. After delivery, the bank rejected several units claiming they failed to meet performance benchmarks. Malcolm argued the rejection rested on subjective preference, but the court applied an objective standard because the components involved mechanical utility measurable by industry specifications and testing protocols.
Meredith Maxwell sold land subject to a covenant limiting future transfers to preserve neighborhood character. The buyer later sought to invalidate the restriction as an unreasonable restraint on alienation. The court weighed the restraint's utility against its burdens and upheld it after finding the limitation advanced measurable property values rather than personal aesthetic preferences.
Maya Malik sued a regulated electric utility after service cutoff for nonpayment under state-approved procedures. She claimed the termination violated due process because the utility functioned as a state actor. The court rejected the claim, holding that monopoly status and regulation alone did not convert routine operational decisions into state action subject to constitutional constraints.
Marcus Mitchell operated a manufacturing plant whose machinery produced steady noise affecting neighboring homes. Residents sued claiming the activity constituted an unreasonable invasion of their land use. The court balanced the gravity of the harm against the conduct's utility and found the plant's operations reasonable because they advanced measurable economic production without feasible alternatives.
Monica Morgan contracted with Midwest Airlines to provide ground transport services using specified vehicle routes. After performance began, the airline rejected several routes as inefficient. The court applied an objective standard to evaluate the routes because they involved mechanical utility and operational fitness that industry experts could measure against time, fuel, and safety benchmarks.
Michael Miller challenged a city zoning rule that restricted occupancy in single-family homes to narrowly defined relatives. He argued the ordinance lacked any rational connection to legitimate goals. The court struck down the restriction after concluding it bore no reasonable relation to preserving neighborhood character or property values and instead imposed arbitrary limits on household composition.
In early 1973, Mrs. Inez Moore received a notice of violation from the city of East Cleveland. The notice stated that her grandson John Moore, Jr., was an illegal occupant of her home. It directed her to comply with the housing ordinance. Mrs. Moore lived in her East Cleveland home together with her son Dale Moore, Sr., and her two grandsons Dale Moore, Jr., and John Moore, Jr. John came to live with her after his mother's death when he was less than one year old. When she failed to remove John from the home, the city filed a criminal charge against her. Mrs. Moore moved to dismiss the charge. She claimed that the ordinance was constitutionally invalid on its face. Her motion was overruled. Upon conviction she was sentenced to five days in jail and a $25 fine. The East Cleveland ordinance limited occupancy of a dwelling unit to members of a single family. The ordinance defined family to include only a husband or wife of the nominal head of the household, unmarried children of the head or spouse provided they have no children residing with them, a parent of the head or spouse, or not more than one dependent child of the head or spouse along with that child's spouse and dependent children. The Ohio Court of Appeals affirmed the conviction after giving full consideration to her constitutional claims. The Ohio Supreme Court denied review of the case. The United States Supreme Court noted probable jurisdiction of her appeal.
View caseThe reasonable person standard governs when the contract concerns commercial quality, operative fitness, or mechanical utility that knowledgeable persons can judge objectively. Good faith applies instead when the subject matter involves personal aesthetics or fancy.
Mechanical utility refers to qualities measurable by external, objective criteria such as industry specifications or testing protocols. Subjective taste involves personal preference that cannot be judged by reference to such standards.
No. When the contract involves mechanical utility, rejection must rest on objective failure to meet measurable standards rather than the buyer's subjective dissatisfaction.
…due process law. This is not surprising, for otherwise a protected liberty could be infringed by a law having no purpose or utility whatsoever. Of course, the current approach is to deal more gingerly with a state statute and to insist that the challenger bear the burden of demonstrating its unconstitutionality; and…