ProfessorMelissa A. Hale
CaseCast™ – "What you need to know"
Brief Fact Summary. The Defendant, Zehmer (Defendant), writes a contract to sell land on a napkin and when the Plaintiff, Lucy (Plaintiff), tries to enforce it, Defendant claims he was only joking.
Synopsis of Rule of Law. If a party to the contract has a reasonable belief that the other party has the requisite intent to enter into the agreement when he does not, the contract is still enforceable.
Issue. Does a valid contract exist?
Held. Yes. Reversed.
The mental assent of the parties is not a requisite for the formation of a contract. If the words or other acts of one of the parties have but one reasonable meaning, his undisclosed intention is immaterial except when an unreasonable meaning which he attaches to his manifestations is known to the other party.
The evidence showed the Plaintiff was warranted in believing the contract represented a serious business transaction and a good faith sale and purchase of the farm. A person cannot say he was joking when his words and conduct would result in a reasonable person believing it was a valid agreement.
Discussion. The court does not look to Defendants intent when making the agreement. The only focus is on the Plaintiff and if he had a reasonable belief. Here, the court is moving away from the requisite “meeting of the minds” standard, in order for there to be a valid contract.