Hoffman v. Chapman
Court of Appeals of
182
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.