Woollums v. Horsley

Court of Appeals of Kentucky, 1892.

93 Ky. 582, 20 S.W. 781.

Dawson, pp. 688-690


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.


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