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Adams v. Lindsell

Court of King’s Bench
106 Eng.Rep. 250 (1818)

Facts

On September 2, 1817, Lindsell (defendant), a dealer in wool, set 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 8th. Lindsell sent the letter to the wrong address, however, and Adams did not receive it until September 5th. That evening, Adams wrote an acceptance of the letter and mailed it back to Lindsell. Lindsell received Adams’ acceptance on September 9th. On September 8th, however, having not received an answer from Adams, Lindsell sold the wool it originally offered to Adams to a third party. Adams brought suit against Lindsell for breach of contract. The trial court held that Adams’ 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 appealed.

Rule of Law

Issue

Holding and Reasoning (Law, J.)

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