Williams v. Walker-Thomas Furniture Co.

198 A.2d 914 · District of Columbia Court of Appeals · 1964

Facts

Appellant, a mother of seven on public assistance, purchased numerous household items from appellee on installment. The contracts contained a clause stating title to all items remained with the seller until the entire balance across all purchases was paid, which appellant claimed she did not understand. Appellee repossessed some items after appellant defaulted, and the trial court ruled in appellee's favor.

Procedural history

Appellee filed a complaint in replevin against appellant. The trial court heard testimony and examined the contracts, subsequently entering judgment for the appellee. Appellant then appealed this decision to the current court.

Issue

Did the installment contracts lack a meeting of the minds due to the appellant's misunderstanding of the terms, or were the contracts unenforceable as against public policy given the seller's knowledge of the buyer's financial hardship?

Holding

The court affirmed the trial court's judgment, finding no lack of meeting of the minds due to the appellant's duty to read the contract, and no existing legal grounds to declare the contracts against public policy in the District of Columbia.

Rule

A party has a duty to read a contract before signing it, and a unilateral mistake or misunderstanding of terms, absent fraud or misrepresentation, does not invalidate the contract. While exploitative contracts may be morally reprehensible, courts cannot declare them against public policy without specific legislative or common law grounds.

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