Adams v. Lindsell

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Adams v. Lindsell
Court High Court of Justice, King's Bench Division
Citation 106 Eng.Rep. 250
Date decided 1818

Facts

Before 1800, parties signed a contract face-to-face. By the early 1800s, making & accepting offers by mail was becoming commonplace.

On September 2nd 1817, Mr. Lindsell mailed a letter to Mr. Adams who was a wool manufacturer.

Adams v. Lindsell, 106 ER 250 (1818).

Facts: Defendant sent, by mail, an offer to sell wool. Due to Defendant's negligence, the offer was received late. Plaintiff immediately accepted, but Defendant had already sold wool.

Issue: Was Plaintiff's purported acceptance actually an acceptance?

Holding: Yes, Plaintiff had accepted.

Reasons: There was a "meeting of the minds" as soon as Plaintiff posted his acceptance in the mail.

Rule: The mailbox rule states that acceptance takes effect as soon as a letter stating such is posted.