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Lucy v. Zehmer

From lawbrain.com

Lucy v. Zehmer, 124 N.Y. 538, 27 N.E. 256 (N.Y. 1891), 196 Va. 493; 84 S.E.2d 516 (1954), is a classic contract case concerning the validity of contract as related to intent.

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Summary of Case Facts

Lucy, the plaintiff, had desired to purchase Zehmer’s (the defendant) farm for some time. Zehmer had, in the past, orally agreed to sell the farm to Lucy, only to later back out. One night, after the consumption of several alcoholic beverages between them, Zehmer agreed to sell Lucy his farm for $50,000. Zehmer wrote out his intention to sell his farm to Lucy on a restaurant bill with the amount of consideration listed, subject to Lucy’s satisfactory examination of the title. He then signed the restaurant bill and had his wife sign it as well. The next day, Lucy hired an attorney to inspect the title for the farm. Finding it to be satisfactory, he contact Zehmer to finalize the sale. Zehmer contended that the sale was merely a joke, and otherwise, his intoxication left him without capacity to enter into the contract. Lucy disagreed and sued for specific performance of the contract.


When examining the validity of a contract, how does a court determine whether one of the parties had the requisite intent to form a contract?

Holding and Law

When examining intent to enter into a contract, the courts look to the reasonable person standard, i.e. what words and actions (objective, outward expression) would lead a reasonable person to believe a party intended to enter into a contract.

In this case, despite the defendant’s contention that the contract was in jest, or that he lacked capacity, the fact that he went to the trouble to write out an agreement, specify the consideration, the parties involved, the subject matter of the contract, address the issue of title, AND get his wife’s consent would lead a reasonable person to believe the intent genuine and the contract valid.

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