Lucy v. Zehmer

Case brief summary

Facts

Zehmer wrote and signed a note agreeing to sell his farm to Lucy for $50,000 while both had been drinking. Zehmer later said he only wrote it as a joke and never meant to sell.

Procedural history

Lucy sued to force Zehmer to complete the sale. The trial court ruled against Lucy and dismissed the case, so Lucy appealed to the Supreme Court of Virginia.

Issue

Did Zehmer and Lucy form a real, enforceable contract to sell the farm, even though Zehmer later said he was only joking when he wrote and signed the note?

Holding

Yes, a binding contract was formed, and the court ordered Zehmer to go through with the sale of the farm to Lucy.

Reasoning

The men seriously discussed the deal for 30-40 minutes and negotiated terms before Zehmer handed over the signed note. Since his words and actions showed serious intent to sell, his private claim it was a joke didn't matter.

Opinions

Majority (Buchanan): A contract is valid if a person's outward words and conduct would reasonably seem serious to the other party, even if that person secretly meant it as a joke.