Stong v. Lane
66 Minn. 94 · Supreme Court of Minnesota · 1896
Facts
Plaintiff sought to buy a lot, and an acquaintance mistakenly pointed out Lot A. Defendant, acting as an agent, had Lot B for sale, which was on the opposite side of the street but similarly described. Plaintiff negotiated with defendant, believing he was buying Lot A, while defendant believed he was selling Lot B. A verbal agreement was made, and plaintiff paid $100, but later discovered the mistake and demanded his money back.
Procedural history
The case was tried before a jury, and the trial judge instructed the jury regarding the necessity of a meeting of the minds for a contract. The current court found no prejudicial error in the trial court's rulings or charge to the jury and affirmed the order.
Issue
Can a buyer rescind a verbal contract for the sale of land and recover a down payment when there was an honest, mutual mistake regarding the identity of the specific lot being sold, despite a legally sufficient but informal description?
Holding
Yes, the court affirmed the lower court's decision, holding that the buyer was entitled to rescind the contract and recover the $100 because there was no meeting of the minds on the subject matter of the contract.
Rule
If parties to a contract have an honest, mutual mistake regarding the identity of the subject matter, especially when the description is informal and ambiguous, there is no meeting of the minds, and thus no binding contract, allowing for rescission.
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