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.

Defendant (Lindsell) sent, by mail, an offer to sell wool. Due to Defendant's negligence, the offer was received late on September 5th 1817.

Plaintiff (Adams) immediately accepted, but Defendant (Lindsell) had already sold wool.

Issues

Was Plaintiff's (Adams) 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.

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