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Lucy v. Zehmer Contract Case Overview

Mar 30, 2025

Lucy v. Zehmer Case Brief

Citation

  • 196 Va. 493, 84 S.E.2d 516 (1954)

Brief Fact Summary

  • Defendant Zehmer wrote a contract on a napkin to sell land.
  • Plaintiff Lucy tried to enforce the contract.
  • Zehmer claimed he was joking.

Rule of Law

  • A contract is enforceable if a party reasonably believes the other party intends to enter into an agreement, regardless of the other party's undisclosed intention.

Facts

  • Plaintiffs sued Defendant for specific performance of a contract to sell 471.6 acres of land for $50,000.
  • The contract was written while the parties were drinking.
  • Zehmer signed the contract but later claimed it was a joke.
  • A waitress testified that Zehmer said he was joking.
  • Plaintiff secured funds from his brother to fulfill the contract.
  • Zehmer later reiterated he was joking after the contract was made.
  • Zehmer's attorneys admitted he was not too drunk to make a contract.

Issue

  • Does a valid contract exist?

Holding

  • Yes. The court held that a valid contract existed.
  • The mental assent of parties is not required if their words/acts have only one reasonable meaning.
  • Plaintiff was justified in believing the transaction was serious.

Discussion

  • The court focused on whether Plaintiff had a reasonable belief in the contract's validity.
  • The decision moved away from the "meeting of the minds" standard for contract validity.

Key Takeaways

  • Actual intent is less important than the reasonable belief of the other party when determining contract enforceability.
  • The case illustrates the objective theory of contract formation.