Cantu v. Central Education Agency

Brief Fact Summary. A question arose as to whether a school district's acceptance of a resignation letter by mail was effective, if there was no authorization in the resignation letter that the school district's reponse may be sent by mail.

Synopsis of Rule of Law. Pursuant to the mailbox rule, "it is proper to consider whether acceptance by mail is reasonably implied under the circumstances, whether or not the offer was delivered by mail."

Facts. The Appellant in this matter was Maria Diosel Cantru, (the "Appellant").  The Appellant was a special-education teacher in the San Benito Consolidated Independent School district.  She had a one year contract for the 1990-1991 school year.  On Saturday, August 18, 1990, the Appellant hand delivered a resignation letter to the school district.  In the letter, the Appellant requested her paycheck be forwarded to a specified address in McAllen, Texas.  The San Benito superintendent of schools, the only individual who could accept letters of resignation on behalf of the school district received the letter on Monday, August 20.  On that same day, the superintendent wrote the Appellant a letter accepting her resignation and mailed it at approximately 5:15pm.  The next day, August 21, at 8:00am, the Appellant hand delivered a letter to the superintendent's office withdrawing her resignation.  This letter included a San Benito return address unlike the first letter, which included a McAllen, Texas address.  T
hat same day, the superintendent hand delivered a letter to the Appellant's San Benito address saying the Appellant's resignation could not be withdrawn.

Issue. What is the proper scope of the "mailbox rule" under Texas law?
•    Was the rule correctly applied by the Commissioner and district court?
•    "Whether authorization to accept by mail may be implied only when the offer is delivered by mail or also when the existing circumstances make it reasonable for the offeree to so accept."

Held. "[T]he mailbox rule, which makes acceptance effective on dispatch, closes the deal and enables performance more promptly, and places the risk of inconvenience on the party who originally has power to control the manner of acceptance."  Whether "the manner of acceptance is reasonable under the circumstances, governs offer and acceptance in commercial transactions under the Texas Business and Commerce Code."
•    No.  The court held that under Texas law, "it is proper to consider whether acceptance by mail is reasonably implied under the circumstances, whether or not the offer was delivered by mail."  The court held, "[t]he Commissioner of Education and district court properly concluded that it was reasonable for the school district to accept Cantu's offer by mail."
•    According to the Restatement and Professor Corbin "an acceptance by any medium reasonable under the circumstances is effective on dispatch, absent a contrary indication in the offer."  The Restatement also recognizes, "that acceptance by mail is ordinarily reasonable if the parties are negotiating at a distance or even if a written offer is delivered in person to an offeree in the same city."

Discussion. This case offers an interesting discussion of one aspect of the "mail box" rule.