Case Citation
Legal Case Name

LUCY v. ZEHMER Case Brief

Supreme Court of Appeals of Virginia1954
84 S.E.2d 516 196 Va. 493 Contracts Property

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Case Brief Summary & Legal Analysis

General Brief
3 min read

tl;dr: A seller claimed a written contract to sell his farm was a joke made while drinking. The court enforced the contract, holding that the seller’s outward actions, not his secret intent, determined that a valid agreement had been formed.

Legal Significance: This case is a canonical illustration of the objective theory of contract formation, establishing that a party’s outward manifestations of assent, as understood by a reasonable person, are sufficient to form a binding contract, regardless of subjective, unexpressed intent.

LUCY v. ZEHMER Law School Study Guide

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Case Facts & Court Holding

Key Facts & Case Background

Plaintiff W. O. Lucy had previously expressed interest in buying the Ferguson Farm from Defendant A. H. Zehmer. On the night of December 20, 1952, Lucy encountered Zehmer at the latter’s restaurant. After both men had consumed alcoholic beverages, Lucy offered Zehmer $50,000 for the farm. Following a discussion lasting approximately 30-40 minutes, Zehmer wrote on the back of a restaurant check, “We hereby agree to sell to W. O. Lucy the Ferguson Farm complete for $50,000.00, title satisfactory to buyer.” Zehmer had revised an initial draft from “I” to “We” at Lucy’s request so that his wife, Ida S. Zehmer, could also sign. Mrs. Zehmer signed the document after her husband whispered to her that it was a joke. Lucy took the written instrument, offered $5 to bind the bargain (which Zehmer refused), and left. Lucy subsequently engaged an attorney to examine the title and arranged for financing. The Zehmers later refused to convey the property, asserting that the agreement was made in jest and that they never intended to sell the farm.

Court Holding & Legal Precedent

Issue: Does a binding and enforceable contract for the sale of real property exist when one party subjectively intends the agreement as a joke, but their words and actions would lead a reasonable person to believe they intended to be legally bound?

Yes, a valid and enforceable contract exists. The court reversed the trial Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute

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IRAC Legal Analysis

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Legal Issue

Does a binding and enforceable contract for the sale of real property exist when one party subjectively intends the agreement as a joke, but their words and actions would lead a reasonable person to believe they intended to be legally bound?

Conclusion

Lucy v. Zehmer is a foundational case in American contract law, cementing Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut

Legal Rule

The formation of a contract is judged by an objective standard. The Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sint occaecat cupidatat non proident, sun

Legal Analysis

The court applied the objective theory of contract formation, focusing not on Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sint occaecat cupidatat non proident, sunt in culpa qui officia deserunt mollit anim id est laborum. Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sint occaecat cupidatat non proident, sunt in culpa qui officia deserunt mollit anim id est laborum. Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sint oc

Flash-to-Full Case Opinions

Flash Summary

  • A party’s unexpressed, subjective intent (e.g., that they are joking) is
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in volup

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