McMichael v. Price, 58 P.2d 549 (OK 1936), was a case decided by the Supreme Court of Oklahoma that held that a constraint on discretion was enough to ensure mutuality of obligation in a requirements contract.

[1] The plaintiff Harley T. Price formed a contract with defendant W.M.

The trial jury found for plaintiff Price, and McMichael appealed.

[3] The Supreme Court of Oklahoma affirmed the verdict for the plaintiff.

McMichael argued that this was an illusory promise because it lacked mutuality of obligation - he contended that the plaintiff could escape all contract liability for simply refusing to sell sand.