Woollums v. Horsley
Court of Appeals of
93
Facts: Woollums was a country bumpkin, and Horsley was a
sophisticated businessman. Horsley was
buying mineral rights in the area, and talked Woollums into selling the rights
to oil, gas, and minerals under his land for a very low price. The trial court awarded specific performance,
and Woollums appealed on the basis that the contract was made through undue
advantage.
Issue: Was the bargain made so unconscionable that specific
performance should not be granted to the plaintiff?
Rule: A court sitting in equity should not grant specific
performance of a contract that is unjust under the circumstances, including
cases of fraud, mistake, and undue advantage.
Analysis: The court finds the gross disparity in sophistication
between the parties and the huge gap between the contract price and the market
price to be strongly suggestive of an unfair deal that they will be slow to enforce
by specific performance. The land
appears to really have been worth $15 per acre based on the value of the
minerals alone, whereas the price offered to Woollums was only 40 cents per
acre.
Conclusion: The judgment of the trial court is reversed and specific
performance is denied.