Organ (plaintiff) was negotiating to buy tobacco from Laidlaw (defendant). Prior to consummation of the sale, Laidlaw asked Organ if he knew of any reason that the market price of tobacco would suddenly change. Organ stated that he did not, but in fact, Organ knew that the War of 1812 had just ended, which almost doubled the market value of the tobacco. Laidlaw was not aware of this fact. The parties completed the sale and Laidlaw delivered the tobacco. However, when Laidlaw heard the news of the war ending, Laidlaw stole the tobacco back from Organ. Organ then brought suit. The trial court granted a directed verdict to Organ, instructing the jury that Organ did not say anything to Laidlaw “calculated to impose upon him with respect to [the news about the war], and to induce him to think or believe that it did not exist.” Laidlaw appealed on the grounds that the jury instructions were improper.