Editing Dickinson v Dodds

{{Infobox Case Brief
|court=Court of Chancery
|citation=2 Ch. D. 463 (1876)
|date=1876
|subject=Contracts
|appealed_from=Property
|facts=This case was litigated in England.

Case in 1 sentence: the early bird catch the worm

On Wednesday, June 10th 1874, John Dodds ("Dodds") [[Contracts/Offer|offer]]ed in writing to sell a residential estate to George Dickinson ("Dickinson"). The written offer would remain open until 9 am, Friday.

Wednesday, June 10th 1874		Dodds offers to sell property with a 9 am Friday deadline
Thursday, June 11th 1874	afternoon	Dickinson returns written acceptance to Dodds while Dodds is out of home
Thursday, June 11th 1874		Dodds & Allen finish property sale
Friday, June 12th 1874	7 am	Dickinson's agent hands duplicate written acceptance to Dodds
Friday, June 12th 1874	about 8 am	Dickinson delivers a 3rd duplicate acceptance to Dodds before the 9 am deadline
Friday, June 12th 1874	about 8 am	Dodds explains to Dickinson that Allen had bought the property yesterday

However, on Thursday of the aforementioned week, Dodds was in the midst of negotiations to sell his property to Thomas Allen. That Thursday, Dickinson delivered a written acceptance to the mother-in-law of Dodds where Dodds was staying (but not at home at the time).

Allen & Dodds signed the real estate contract on Thursday, June 11th 1874.

{{Timeline|1=Dodds offers to sell property with a 9 am Friday deadline|2=Wednesday, June 10th 1874|4=Dickinson returns written acceptance to Dodds while Dodds is out of home|3=Thursday afternoon, June 11th 1874|5=Dodds & Allen finish property sale|6=Thursday, June 11th 1874|8=Dickinson's agent hands duplicate written acceptance to Dodds|7=7 am Friday, June 12th 1874|9=Dickinson delivers a 3rd duplicate acceptance to Dodds before the 9 am deadline|10=About 8 am Friday, June 12th 1874|12=Dodds explains to Dickinson that Allen had bought the property yesterday|11=About 8 am Friday, June 12th 1874}}
|procedural_history=*Dickinson = plaintiff = buyer1
*Allen = buyer2 = defendant
*Dodds = defendant = property seller


Dickinson sued Dodds & Allen.

Dickinson won in the trial court because Dickinson delivered his acceptance before the 9 am, Friday, June 12th 1874 deadline.
|issues=1. Can an offerree (Dickinson) enforce an offeror's (Dodds) promise to hold an offer open for a definite time?

2. Can such an offer be revoked without an express statement?
|holding=Lord Justice James: A promise to hold an offer open is not enforceable without [[Contracts/Consideration|consideration]], & it can be implied revoked by the offeror's conduct.
|judgment=Judgment reversed; complaint from Dickinson dismissed.
|reasons=Lord Justice James: The timeframe to sell was part of the general offer, & therefore, not binding unless validly accepted.

Dickinson hadn't offered Dodds anything to hold the offer open. In other words, Dickinson had not given any consideration (anything of value).
|rule="A meeting of the minds": A moment in time, preceding the contract, during which the 2 parties' minds are in agreement.

In this case, a meeting of the minds of Dickinson & Dodds didn't occur before the sale of the property from Dodds to Allen.

As of 2024, '''option contract'''s ( https://www.law.cornell.edu/wex/option_contract ) in the United States are available yet require consideration.
|comments=Lord Justice James: Dodds (seller who gave a timeframe to sell his property) wasn't required to formally notify Dickinson that the offer was withdrawn before the 9 am, Friday deadline.
|case_text_links={{Infobox Case Brief/Case Text Link
|link=https://www.quimbee.com/cases/dickinson-v-dodds
|source_type=Video summary
|case_text_source=Quimbee
}}{{Infobox Case Brief/Case Text Link
|link=https://law.justia.com/cases/foreign/united-kingdom/2-ch-div-463-1876.html
|case_text_source=Justia
}}
}}