Hoffman v. Chapman

Court of Appeals of Maryland, 1943.

182 Md. 208, 34 A.2d 438.

Dawson, pp. 497-499


Facts: The Chapmans agreed to sell part of a lot to the Hoffmans.  Both parties understood that only a part of the lot was being sold.  By mistake, the deed was written up such that it conveyed the entire lot.  The Chapmans asked the Hoffmans to convey back the part of the lot that they weren’t meant to get, but the Hoffmans refused.  The Chapmans sued in equity to have the deed reformed to fix the mistake and to reflect the intent of the parties.  The trial court granted the Chapmans a decree reforming the deed.  The Hoffmans appealed.


Issue: Can the contract for the sale of the part of the lot be properly reformed?


Rule: A court will reform a writing when there is evidence beyond a reasonable doubt that a “mutual mistake was made…contrary to their agreement”.


Analysis: The appellants don’t really dispute the facts so much as the law.  First they claim that there was no meeting of the minds as to the location of the parcel for sale.  However, the court finds that there was no mistake as to what property was for sale, but merely an error in writing down the agreement.  Therefore, the argument holds no water.


Next, the appellants say they weren’t at fault and so they shouldn’t have to suffer the consequences.  The court says, however, that fault or negligence is irrelevant in this case so long as no legal duty was broken.


Finally, the court says that equity will tend to favor reformation of a writing when the mistake in writing was mutual or the fault of a third party.


Conclusion: The trial court’s decree is affirmed.


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