Laidlaw v. Organ

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Laidlaw v. Organ
Court Supreme Court of the United States
Date decided March 15, 1817


British embargo of American exports were still in effect as of 1815. Without access to British markets, prices for American tobacco were depressed.

In February 1815, Mr. Organ was negotiating to purchase tobacco from Laidlaw & Company. However, the night before, Organ had learned that a peace treaty had been signed between Britain & America. (In those days, news would take a long time to travel.)

Organ knew that as soon as the news reached Laidlaw in the United States, tobacco prices would go up because of the new demand from the British market.

Organ told Laidlaw that he knew nothing about any pending market prices while completing the transaction to buy 111 hogsheads of tobacco (120,000 pounds or about 55 tons) in Louisiana.

Once the news of the peace treaty began widely circulating in newspapers in the area on February 19th 1815, the value of tobacco skyrocketed by 40%.

The next day, Laidlaw henchmen stole back their tobacco delivery from Organ by force!

Procedural History

Organ sued Laidlaw seeking the return of the tobacco.

Jury found for Organ in the trial court.


Do parties have a duty to disclose important information regarding a contract?


John Marshall with a unanimous court: A party does not have any obligation to share the important information.

However, a party cannot lie or actively mislead.