Mailbox Rule

Case: ADAMS v. LINDSEL (England, Court of King’s Bench, 1818), p. 320

Facts: Defendants sent plaintiffs a letter offering to sell a specific amount of

wool for s specified amount.
On 9/2 - defendants mailed out the letter, but misdirected it, which delayed
the time it took for plaintiffs to receive it.
On 9/5 (fri, at 7pm) - the plaintiff received the letter of offer. Same
evening, plaintiff wrote an answer , agreeing to accept the offer.
On 9/8 - def's, not having rec'd an answer by 9/7 (which they would have in
the normal course of post, but they had misdirected their offer letter), and sold
the product to another buyer
On 9/9 (tues) - the defendants received the acceptance letter
Plaintiff seeks performance of the contract.

Issue: When was the plaintiff's acceptance valid?

Whether the plaintiffs still had the power to accept after the defendants voided
the offer when selling the wool to a third party. - yes, still had power to
accept.

Holding: Plaintiffs recovered a verdict.

Reasoning: the delay was caused by the defendants, and so if there was no mistake
on part of def's, the acceptance would have been rec'd by 9/7, before def sold
wool to a third party. Also, court says the Defendants must be considered in law
to be making the same identical offer to the Plaintiffs at every instant the
letter is in route, and the contract is completed by acceptance by the Plaintiff.
If the Defendants were not bound by their offer after acceptance by the Plaintiffs
until answer was received, then the Plaintiffs ought not to be bound until they
receive notice of the Defendant’s receipt and assent to that, and so on and so on.
There would be no end!

RULE: an acceptance of an offer is valid once it is mailed.

Notes

What's the purpose of the mailbox rule? - if no default rule like this, it would
become a continuous circle, keep sending out offers, etc. Gives some definiteness
to the formation of the contract
Mailbox rule is a default rule. Parties can set their own rules, but if not
specified, court will use this rule.