Lucy v. Zehmer – Case Brief
Lucy v. Zehmer, 196 Va. 493, 84 S.E.2d 516 (1954).
Facts: One evening in December 1952 after several drinks, Zehmer (D) wrote a contract on a restaurant bill in which he agreed to sell his farm to Lucy (P) for $50,000. D later insisted that he had been intoxicated and thought the matter was a joke, not realizing that P had been serious.
Issue: Was an enforceable contract formed?
Holding and Rule: Yes. The court held that the court must look to the outward expression of a person as manifesting his intention rather than to his secret and unexpressed intention. In other words, whether a party had the requisite intent to enter into an enforceable contract is determined by the acts of that party and not the party’s actual subjective intent. The court decided that D’s acts appeared to manifest an intent to enter into a binding contract and held the contract valid. “The law imputes to a person an intention corresponding to the reasonable meaning of his words and acts.”
Rule: If the words or other acts of one of the parties have but one reasonable meaning, his undisclosed intention is immaterial except when an unreasonable meaning which he attaches to his manifestations is known to the other party.
Disposition: Reversed and remanded