Cantu v. Central Education Agency
884 S.W.2d 565 · Court of Appeals of Texas · 1994
Facts
Maria Diosel Cantu was hired as a special-education teacher by the San Benito Consolidated Independent School District for the 1990-91 school year. On Saturday, August 18, 1990, Cantu hand-delivered a letter of resignation, effective August 17, 1990, to her supervisor, requesting her final paycheck be forwarded to an address 50 miles away. The superintendent, the only official authorized to accept resignations, received the letter on Monday, August 20. That same day, the superintendent mailed a letter accepting Cantu's resignation at approximately 5:15 p.m. The next morning, August 21, at 8:00 a.m., Cantu hand-delivered a letter withdrawing her resignation. In response, the superintendent hand-delivered a copy of his acceptance letter, informing Cantu her resignation had been accepted and could not be withdrawn.
Procedural history
Appellant Maria Diosel Cantu sued for judicial review of a final order by the State Commissioner of Education, Lionel Meno. The district court affirmed the Commissioner’s decision. This court is reviewing the trial-court judgment.
Issue
The legal question is the proper scope of the "mailbox rule" under Texas law. Specifically, whether authorization to accept an offer by mail may be implied only when the offer is delivered by mail, or also when existing circumstances make it reasonable for the offeree to accept by mail.
Holding
The court affirmed the trial court's judgment, holding that the school district's acceptance of Cantu's resignation was effective when mailed. This meant an agreement to rescind her employment contract was in force before she attempted to withdraw her offer of resignation.
Rule
The mailbox rule makes acceptance effective on dispatch, closing the deal and allocating risk. Acceptance by mail is impliedly authorized if reasonable under the circumstances, even if the offer was not made by mail or there was no express authorization. The Restatement (Second) of Contracts supports this, stating acceptance by any reasonable medium is effective on dispatch. Reasonableness can be indicated by parties negotiating at a distance or other circumstances, such as the need for immediate action and the offeror's indication of distance. The court rejected a rigid interpretation that implied authorization only occurs if the offer was sent by mail.
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