ProfessorMelissa A. Hale
CaseCast™ – "What you need to know"
Brief Fact Summary. Defendant William G. Eurice & Bros., Inc., entered into a contract to build a house for Plaintiff Ray. After signing the contract, the parties disagreed as to which specifications were to be used.
Synopsis of Rule of Law. Unilateral mistake, unlike mutual mistake, does not prevent the meeting of the minds required for contract formation.
The rule is that if there is no fraud, duress or mutual mistake, one who has the capacity to understand a written document who reads and signs it, or, without reading it or having it read to him, signs it, is bound by his signature as to all of its terms.View Full Point of Law
Issue. Did the parties create an enforceable contract to build a house?
Held. Yes. The unilateral mistake of Defendant did not prevent the formation of an enforceable contract.
The Court notes that a party will not be bound by their signature where there is fraud, duress, or mutual mistake. The trial court found that the mistake as to what specifications would be used prevented a meeting of the minds, thereby preventing the formation of an enforceable contract between the parties.
On appeal, the Court viewed the mistake differently. The Court reasoned that the mistake, if any, was unilateral. The contract clearly indicated which specifications were to be used. Also, Defendant had access to the specifications and even signed the back of the specifications at one point. Because only Defendant was mistaken as to the specifications to be used, the mistake was unilateral. A unilateral mistake does not prevent the formation of an enforceable contract.
Discussion. In the present case, Defendant argued that a contract was not formed because the parties did not agree to the same specifications. The Court determines that the contract clearly indicated which specifications were to be used and that if there was a mistake, it was only on the part of Defendant. Because the mistake was unilateral, not bilateral, the mistake did not prevent the parties from creating an enforceable contract.