Review of a United States District Court Decision under the CISG regarding Conformity of Goods - Chicago Prime Packers v. Northam Food Trading Co. -

The United Nations Convention on Contracts for the International Sale of Goods (the CISG) has been incorporated into the federal legal system of the U.S. since 1988. The number of U.S. court decisions governed by the CISG has been recently increasing. However, some of them have been criticized for the "homeward trend," which goes against the demands of the CISG's Article 7(1) to consider the international character and the need to promote uniform application of the CISG. This paper reviews the decisions of a federal district court in Chicago Prime Packers v. Northam Food Trading Co. pertaining to conformity of goods. The Court's holdings were in general proper and adequate in interpreting the CISG. Further, in light of the fact that many U.S. courts have relied solely on domestic precedents when interpreting the CISG, the Court's reference to many foreign decisions should be highly regarded as fulfilling the demands of Article 7(1). It is hoped that more courts, by referring to Chicago Prime, will consider the international character and the need for uniform application of the CISG in the future.