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Harcourt Brace Jovanovich, Inc. v. Goldwater
District Court, S.D. New York (1982) | 532 F. Supp. 619; 8 Media L. Rep. (BNA) 1217; 1982 U.S. Dist. LEXIS 10891
TL;DR: A publisher rejected an author's manuscript using a "satisfaction clause" but was found to have breached the contract. The court held the publisher's failure to provide any editorial feedback violated its implied duty of good faith, making the rejection wrongful.
Legal Significance: This case establishes that a publisher's right to reject a manuscript under a "satisfaction clause" is limited by an implied duty of good faith, which requires providing the author with editorial feedback and a reasonable opportunity to cure defects before rejection.