Lewis v. Browning

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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).