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Adams v. Lindsell

High Court of Justice, King's Bench Division

106 Eng.Rep. 250 (1818)

Facts

On September 2, 1817, Lindsell (defendant), a dealer in wool, sent a letter to Adams (plaintiff), a manufacturer of wool, offering to sell Adams a certain amount of wool. The offer provided for acceptance by written notice sent through regular mail (“in course of post”). Based on the timing of sending the letter, Lindsell expected to receive a response from Adams by September 7th. However, Lindsell sent the letter to the wrong address, and Adams did not receive the letter until September 5th. That evening, Adams wrote an acceptance of the offer and mailed it back to Lindsell. Lindsell received Adams’s acceptance on September 9th. However, because Lindsell had not received a response from Adams as expected on September 7th, Lindsell sold the wool it had originally offered to Adams to a third party on September 8th. Adams brought suit against Lindsell for breach of contract. The trial court held that Adams’s acceptance was valid when placed by Adams in the mail, and that any delay in receiving the acceptance was caused by Lindsell’s failure to send the initial offer to the correct address. The trial court entered judgment for Adams, and Lindsell moved for a new trial.

Rule of Law

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Issue

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Holding and Reasoning (Ellenborough, LCJ)

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