Rotenberry v. Hooker
| Docket Number: | 2002-CA-00096-SCT Linked Case(s): 2002-CA-00096-SCT ; 2002-CA-00096-SCT |
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| Supreme Court: | Opinion Link Opinion Date: 11-06-2003 Opinion Author: Waller, J. Holding: Affirmed |
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| Additional Case Information: |
Topic: Contract - Specific performance - Meeting of the minds - Doctrine of unilateral mistake - Unconscionable advantage Judge(s) Concurring: Pittman, C.J., Smith, P.J., Easley, Carlson and Graves, JJ. Non Participating Judge(s): Cobb and Diaz, JJ. Dissenting Author : McRae, P.J. Procedural History: Bench Trial Nature of the Case: CIVIL - CONTRACT |
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| Trial Court: |
Date of Trial Judgment: 12-20-2001 Appealed from: Hinds County Chancery Court Judge: Denise Owens Disposition: Denied the Appellant's claim for specific performance. Case Number: G 99-182 (0-3) |
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| Party Name: | Attorney Name: | |||
| Appellant: | Clinton Grice Rotenberry, Jr. |
VAUGHN DAVIS |
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| Appellee: | Scottye R. Hooker | DANA J. SWAN |
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Synopsis provided by:  If you are interested in subscribing to the weekly synopses of all Mississippi Supreme Court and Court of Appeals hand downs please contact Tammy Upton in the MLI Press office. |
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| Topic: | Contract - Specific performance - Meeting of the minds - Doctrine of unilateral mistake - Unconscionable advantage |
| Summary of the Facts: | Scottye Hooker and Clinton Rotenberry, Jr., were sole and equal beneficiaries of a trust. Hooker made an offer to sell Rotenberry her one-half interest in a farm held by the trust. Rotenberry accepted the offer, but Hooker rejected the acceptance. Rotenberry filed a claim for specific performance which the court denied. Rotenberry appeals. |
| Summary of Opinion Analysis: | Issue 1: Meeting of the minds Rotenberry argues that the chancellor erred in finding there was no meeting of the minds as to the price in the agreement and allowing extrinsic evidence. The contract fails when the price has not been stated with specificity. If the language in the contract is clear and unambiguous the intent of the contract must be effectuated. Hooker's original letter which offered to sell her half of the farm states "the price less the amount due Met Life." The letter does not indicate that Hooker would only pay one-half of the amount owed Met Life. Since the letter was clear and unambiguous the chancellor should not have looked outside its four corners. Once accepted by Rotenberry, Hooker's letter offering to sell her interest in the land created a valid agreement. Issue 2: Doctrine of unilateral mistake Rotenberry argues that the chancellor erred in finding that Hooker was entitled to recission of the contract due to unilateral mistake. Equity will prevent an intolerable injustice such as where a party has gained an unconscionable advantage by mistake and the mistaken party is not grossly negligent. The chancellor reviewed the dealings between the parties and found that neither party had an obligation to pay any more than one-half of the debt. A mistake to the tune of $230,000 bestows an unconscionable advantage upon Rotenberry. The chancellor recognized the fundamental injustice of holding Hooker to such an obligation and as such, her findings were not manifestly erroneous. |
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