BAR EXAM (UNIFORM) • CONTRACTS

Governing Law — Determine whether common law or UCC governs

The threshold question in every contracts analysis: identifying whether common law or Article 2 of the UCC applies.

Historical Context & Motivation

Before a single issue of offer, acceptance, or breach can be analyzed on a contracts question, a preliminary threshold inquiry must be resolved: which body of law governs the transaction? American contract law developed along two parallel tracks. The common law of contracts, rooted in centuries of English judicial decision-making, evolved through case-by-case adjudication and was eventually synthesized in the Restatement (Second) of Contracts (1981). Meanwhile, the rapid growth of commercial trade in the twentieth century exposed the inadequacy of common law rules for transactions involving the sale of tangible goods, prompting the creation of a statutory framework specifically designed for merchants and commercial parties.

1896
Uniform Sales Act Drafted
The National Conference of Commissioners on Uniform State Laws (NCCUSL) promulgated the Uniform Sales Act, an early attempt to harmonize state laws governing the sale of goods across jurisdictions.
1952
UCC Article 2 Approved
Karl Llewellyn and the American Law Institute published the Uniform Commercial Code. Article 2, governing the sale of goods, replaced the Uniform Sales Act and introduced modern concepts such as the merchant's firm offer and the perfect tender rule.
1958–1968
Widespread State Adoption
Nearly every state enacted Article 2, making it the dominant statutory regime for the sale of goods. Louisiana remains the only state that has not adopted Article 2 in full, relying instead on its civil-law tradition.
1981
Restatement (Second) of Contracts
The American Law Institute published the Restatement (Second), consolidating common law principles applicable to contracts for services, real estate, employment, and all other non-goods transactions.
2003
Proposed Revised Article 2
The ALI and NCCUSL approved a revised Article 2, but no state adopted it. The 2003 revision was ultimately withdrawn in 2011, leaving the original 1952 text (with minor amendments) as controlling law.

This dual-track development means that American contract law is not monolithic. A contract for the construction of a building is governed by entirely different default rules than a contract for the purchase of steel beams used in that building. On the bar exam, correctly identifying the governing body of law is the gateway to the entire analysis—an error at this stage can cascade through every subsequent issue, from formation to remedies. The central question, then, is deceptively simple: Is this a transaction in goods?

Core Principles & Definitions

The determination of governing law rests on a set of foundational definitions drawn from UCC § 2-105 and general common law doctrine. Understanding these definitions is essential because the bar exam frequently tests borderline scenarios—such as mixed contracts involving both goods and services—where the classification is outcome-determinative. The following core concepts form the analytical framework that every contracts question demands.

1

Goods (UCC § 2-105)

All things that are movable at the time of identification to the contract. This includes manufactured products, crops, livestock, and specially manufactured items, but excludes real property, money exchanged as the price, and investment securities.
2

Common Law Subjects

All contracts that do not involve the sale of goods fall under common law: services, real estate transactions, employment agreements, insurance contracts, and intellectual property licenses are the most frequently tested categories.
3

The Predominant Purpose Test

When a contract involves both goods and services (a 'mixed' or 'hybrid' contract), the majority of jurisdictions apply the predominant purpose (or predominant factor) test: whichever component—goods or services—forms the primary thrust of the agreement governs the entire contract.
4

Merchant Status (UCC § 2-104)

Under the UCC, certain heightened obligations apply to merchants—parties who deal in goods of the kind or who hold themselves out as having special knowledge. Merchant status is a secondary inquiry, but it only becomes relevant after the UCC is determined to govern.
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Key Doctrinal Differences

The choice between common law and UCC is not merely academic. It affects rules on acceptance (mirror image rule vs. UCC § 2-207), the statute of frauds threshold ($500), modification (consideration required vs. good faith), and available remedies.
KEY TAKEAWAY
Think of the governing-law determination as choosing which rulebook to use before a game starts. If you apply the common law 'mirror image rule' to a transaction actually governed by UCC § 2-207, you will reach the wrong conclusion on whether a contract was formed—just as applying basketball rules on a football field would produce nonsensical results. The first move in any contracts analysis is always: identify the subject matter of the contract and select the correct body of law.

Visual Decision Framework

This decision tree illustrates the analytical path for determining governing law. Begin at the top by identifying the subject matter of the transaction. Pure goods transactions trigger the UCC; pure service, real estate, or other non-goods contracts fall under common law. For mixed contracts, apply the predominant purpose test, examining the factors listed at the bottom of the diagram.

The diagram above captures the analytical structure that should guide every bar exam contracts question. Note that the flowchart is strictly hierarchical: the subject matter inquiry always comes first. Only when a contract involves both goods and services does the analysis require the additional step of applying the predominant purpose test. A common error on the MBE is failing to perform this threshold analysis altogether, leading examinees to apply UCC rules (such as the battle of the forms under § 2-207) to what is actually a common law services contract.

How the Classification Works — Distinguishing Goods from Non-Goods

Defining "Goods" Under UCC § 2-105

The statutory definition is deceptively straightforward. Under UCC § 2-105(1), goods are defined as "all things (including specially manufactured goods) which are movable at the time of identification to the contract for sale." Several important principles flow from this definition. First, the test is temporal: the item must be movable at the time it is identified to the contract, not at some earlier or later moment. Second, the test focuses on tangibility and movability—intangible rights such as patents, copyrights, and contract rights are excluded. Third, certain items that might seem like goods are expressly excluded: money used as the medium of exchange (though rare coins sold as collector's items qualify as goods), investment securities governed by Article 8, and things in action.

Borderline Categories

Borderline categories frequently tested on the bar exam
CategoryClassificationRationale
Growing cropsGoods (UCC)Crops are movable once harvested and are identified to the contract while still growing. UCC § 2-107(2).
Timber, minerals, structures to be severed by sellerGoods (UCC)When the seller is to sever them from realty, they are treated as goods. UCC § 2-107(1).
Timber, minerals severed by buyerReal property (Common Law)When the buyer is to sever, the contract is treated as a real property transaction.
Software (custom-developed)Likely services (Common Law)Most courts treat custom software as predominantly a service contract. But off-the-shelf, mass-produced software on physical media is often treated as goods.
Blood transfusionsService (Common Law)Most jurisdictions have enacted "blood shield" statutes classifying blood transfusions as services, not sales of goods, to shield hospitals from strict liability.
ElectricitySplit of authoritySome courts classify electricity as a good (it is metered and sold in units); others treat it as a service.

The Predominant Purpose Test in Detail

The leading case on the predominant purpose test is Bonebrake v. Cox (8th Cir. 1974), which held that a court should look to the contract as a whole to determine whether its predominant factor, thrust, or purpose is the rendition of a service or the sale of goods. Courts examine multiple factors: the language of the contract (does it describe "goods sold" or "services rendered"?), the nature of the supplier's business (is the supplier primarily a manufacturer/retailer or a service provider?), the relative value allocated to goods versus services, and the basis of the complaint or breach. A minority of jurisdictions apply the gravamen test, which examines not the contract as a whole but the specific aspect of the transaction that is the source of the complaint. Under this approach, if the buyer's complaint relates to defective goods, Article 2 governs that issue even if the contract as a whole is predominantly for services. The MBE, however, overwhelmingly tests the majority predominant purpose approach.

⚖️ BAR EXAM TIP
When you see a fact pattern involving installation, repair, or professional services combined with the supply of materials or parts, immediately flag this as a mixed contract. Ask: "Was the buyer primarily seeking the goods themselves, or the provider's skill and labor?" A contract to purchase a custom-built wedding cake is predominantly for goods; a contract to hire a caterer for a wedding reception (who also supplies food) is predominantly for services.

Why It Matters — Key Doctrinal Differences Between Common Law and UCC

The classification of governing law is not an abstract exercise. It determines which set of substantive rules applies to every stage of the contracting process—from formation to performance to remedies. The following diagram and table illustrate the most significant divergences, many of which are frequently tested on the MBE and MEE.

A side-by-side comparison of the six most frequently tested doctrinal differences between common law (left, pink) and UCC Article 2 (right, cyan). Identifying the correct governing law determines which column of rules applies.

As the diagram illustrates, the consequences of misidentifying governing law are substantial. Consider modification: under common law, an agreement to modify a contract requires fresh consideration—the pre-existing duty rule. Under UCC § 2-209, no new consideration is required so long as the modification is made in good faith. If an examinee applies the wrong body of law, the analysis of whether a valid modification occurred will be fundamentally flawed. Similarly, the acceptance rules diverge dramatically: where common law's mirror image rule treats any variant acceptance as a counteroffer, UCC § 2-207 permits a definite expression of acceptance to form a contract even when it includes additional or different terms—the so-called "battle of the forms."

Worked Example — Classifying a Contract

Consider the following fact pattern, representative of MBE-style questions: HomeOwner contracts with BuilderCo to renovate her kitchen. The contract states that BuilderCo will design and install custom cabinetry, granite countertops, and new appliances. The total contract price is $50,000, with $35,000 allocated to materials and appliances, and $15,000 to design and labor. A dispute arises when the countertops arrive with visible cracks. Which body of law governs?

Determining Governing Law: Kitchen Renovation Contract
1
Step 1 — Identify the Subject MatterThe contract involves both the supply of tangible, movable items (cabinetry, countertops, appliances—all "goods" under UCC § 2-105) and the provision of services (design expertise and installation labor). Because both goods and services are present, this is a mixed contract requiring the predominant purpose test.
Classification: Mixed contract (goods + services)
2
Step 2 — Apply the Predominant Purpose TestExamine the factors identified in Bonebrake v. Cox. First, the contract language describes both materials to be "supplied" and design services to be "rendered." Second, the relative value favors goods: $35,000 of the $50,000 price (70%) is allocated to materials and appliances. Third, the nature of BuilderCo's business—a renovation contractor—suggests it provides both goods and services, but the primary deliverable the homeowner is paying for could be characterized either way.
3
Step 3 — Weigh the FactorsThe 70% allocation to goods is significant. A court would likely find that the predominant purpose of this contract is the transaction in goods. The homeowner's primary objective was to obtain specific physical products—custom cabinets, stone countertops, and appliances—with installation being incidental to that objective. The basis of the complaint (cracked countertops) also points to a goods-related deficiency.
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Step 4 — ConclusionBecause the predominant purpose of the contract is the sale of goods, the entire contract—including the services component—is governed by UCC Article 2. This means the homeowner can invoke the perfect tender rule (§ 2-601) to reject the nonconforming countertops, implied warranties of merchantability (§ 2-314) and fitness for a particular purpose (§ 2-315) apply, and the statute of frauds threshold is $500 under § 2-201.
Governing Law: UCC Article 2
CONTRAST
If the same homeowner contracted with an interior designer who, as part of a full design consultation, also ordered some furniture from a supplier, the predominant purpose would likely be the designer's professional services. In that scenario, common law would govern. The takeaway: identical physical goods can be classified differently depending on the overall thrust of the contract.

Predominant Purpose Test vs. Gravamen Test

While the predominant purpose test is the majority approach and the one most frequently tested on the bar exam, it is important to understand its alternative. The gravamen test takes a fundamentally different approach to mixed contracts. Rather than applying a single body of law to the entire contract, the gravamen test looks at the specific source of the complaint or issue in dispute. If the complaint stems from a defect in the goods component, the UCC governs that issue; if it stems from deficient services, common law governs. This issue-specific approach has been adopted by a minority of courts, but most bar review materials—and the MBE—default to the predominant purpose test unless otherwise indicated.

Comparison of the two approaches to mixed contracts
FeaturePredominant Purpose Test (Majority)Gravamen Test (Minority)
Unit of analysisThe contract as a wholeThe specific issue or complaint in dispute
Governing law outcomeOne body of law governs the entire contractDifferent bodies of law may govern different aspects of the same contract
AdvantagePredictability and simplicity; avoids applying two legal frameworks to one transactionTailored analysis; applies the more appropriate body of law to each issue
DisadvantageMay apply an ill-fitting body of law to one component (e.g., UCC perfect tender rule to a services issue)Complexity; potential inconsistency in applying two sets of rules to one contract
Leading authorityBonebrake v. Cox, 499 F.2d 951 (8th Cir. 1974)Anthony Pools v. Sheehan, 455 A.2d 1002 (Md. 1983)
Bar exam defaultTested as the default approachRarely tested; may appear as a wrong answer choice
KEY TAKEAWAY
Think of the predominant purpose test like classifying a restaurant meal: even though the restaurant provides both food (goods) and service (preparation, ambiance, table service), a typical dine-in experience is predominantly a service transaction. A take-out order from the same restaurant, however, might tip toward a goods transaction because the customer is primarily acquiring the food itself. The gravamen test, by contrast, would ignore the overall classification and simply ask: "Is the customer complaining about the food (goods) or the service?" On the bar exam, always default to the predominant purpose test unless the question specifically indicates otherwise.

Connections to Advanced Issues & Other UCC Articles

Once a student masters the Article 2 vs. common law distinction, several advanced issues emerge. First, Article 2 does not exist in isolation: the broader UCC contains articles governing leases of goods (Article 2A), negotiable instruments (Article 3), and secured transactions (Article 9), each with its own scope and definitions. Second, the international analog of Article 2—the United Nations Convention on Contracts for the International Sale of Goods (CISG)—applies to cross-border sales of goods between parties in signatory nations unless the parties expressly opt out. While the CISG is less heavily tested on the bar exam, understanding its existence is important for any contracts analysis involving international parties.

From Article 2 basics to advanced extensions
ConceptArticle 2 (Basic)Advanced Extension
ScopeSale of goodsArticle 2A extends analogous rules to leases of goods; CISG governs international sales
Merchant rules§§ 2-104, 2-205, 2-207, 2-209Article 2A also has merchant-specific provisions for lease transactions
Digital goods / SaaSUncertain; most courts treat as non-goodsProposed UCITA (Uniform Computer Information Transactions Act) was withdrawn; no uniform statute governs software licenses
Mixed contractsPredominant purpose testEmerging question: should 3D-printed goods, which are manufactured on-site through a service process, be treated as goods or services?

The digital economy poses particularly interesting challenges to the traditional goods/services dichotomy. When a consumer downloads software from the internet, there is no tangible, movable object—yet the transaction resembles a sale. When a business subscribes to a cloud-based Software-as-a-Service (SaaS) platform, the transaction has characteristics of both a license and a service agreement. These frontier questions are unlikely to appear on the current bar exam, but they illustrate why mastering the foundational classification framework is essential: as commerce evolves, the core analytical question—"Is this a transaction in goods?"—remains the starting point for every analysis.

Practice Problems

PROBLEM 1CONCEPTUAL
A law student argues that the UCC should govern a contract for the sale of a house because a house is a "thing" and Article 2 governs "all things." What is the flaw in this reasoning?
PROBLEM 2BASIC APPLICATION
Farmer agrees to sell 500 bushels of wheat from next season's harvest to GrainCo for $4,000. Is this contract governed by the UCC or common law? Does the fact that the wheat has not yet been grown affect the analysis?
PROBLEM 3INTERMEDIATE
An artist enters into a contract with a client to create a custom oil painting for $8,000. The contract specifies that the artist will supply all materials (canvas, paint, frame) valued at $1,200 and will devote approximately 120 hours of labor to the project. The client later rejects the finished painting, claiming it does not match the agreed-upon specifications. Which body of law governs, and what performance standard applies?
PROBLEM 4APPLIED
TechCorp contracts with PrintShop to print 10,000 custom marketing brochures. The contract price is $15,000. PrintShop designs the layout (using TechCorp's brand guidelines), sources the paper stock, and prints and delivers the brochures. After delivery, TechCorp discovers that the color on 2,000 brochures is slightly off-specification. TechCorp wants to reject the entire shipment. Determine the governing law and analyze whether TechCorp can reject all 10,000 brochures.
PROBLEM 5CRITICAL THINKING
A hospital purchases a diagnostic MRI machine from MedDevice Inc. for $2 million. The contract includes delivery, installation, calibration, a two-year service warranty, and training for hospital staff. The installation and training are valued at $300,000. Six months later, the MRI malfunctions due to a manufacturing defect. Under the predominant purpose test, common law would govern because the hospital's primary purpose was to obtain a functioning diagnostic service, not merely to acquire a physical machine. Evaluate this argument. Is the assertion correct?

Lesson Summary

The threshold question in every contracts analysis on the bar exam is determining the governing body of law. UCC Article 2 governs contracts for the sale of goods—defined as all things that are movable at the time of identification to the contract. Common law governs everything else: services, real estate, employment, insurance, and intellectual property contracts. When a contract involves both goods and services (mixed contracts), the majority rule requires applying the predominant purpose test to determine which component—goods or services—forms the primary thrust of the agreement, and then applying that body of law to the entire contract.

Getting this classification right is outcome-determinative because the UCC and common law diverge on critical issues: the mirror image rule vs. § 2-207 for acceptance, consideration for modification vs. good faith, the $500 statute of frauds threshold, firm offers without consideration, gap-fillers for open terms, and the perfect tender rule vs. substantial performance. Always begin your contracts analysis by identifying the subject matter and selecting the correct legal framework before addressing any substantive issue.

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