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.


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|3=Dickinson returns written acceptance to Dodds while Dodds is out of home|4=Thursday afternoon, June 11th 1874|5=Dodds & Allen finish property sale|6=Thursday, June 11th 1874|7=Dickinson's agent hands duplicate written acceptance to Dodds|8=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|11=Dodds explains to Dickinson that Allen had bought the property yesterday|12=About 8 am Friday, June 12th 1874|13=|14=|15=|16=|17=|18=}}
|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
}}
}}