Lewis v. Browning
Lewis v. Browning, 130 Mass. 173 (1881).
Facts: Plaintiff's offer letter said acceptance should be made by telegraph by a certain date. Plaintiff received acceptance after that date.
Issue: Was a contract formed?
Holding: No, the terms of Plaintiff's offer was not met. Mailbox rule does not apply.
Rule: The mailbox rule does not apply, because the offer clearly outlined that acceptance only occurred upon receipt (by the deadline).