Supreme Court of the United States
Willard v. Tayloe
January 24, 187075 U.S. 557
Summary
The Court held that the lease option constituted a continuing offer supported by consideration and became an enforceable contract when accepted by the lessee. Although specific performance rests in equitable discretion, the Court concluded that enforcement would not be unjust, but conditioned the conveyance on payment in gold or silver and execution of security for deferred installments. The Chief Justice, joined by Nelson, J., concurred in the result but did not agree with the reasoning supporting the required currency.
Holding
- Whether the lease option created an enforceable contract of sale upon acceptance.. The option was a continuing offer to sell supported by the sealed covenant, and Willard's timely acceptance completed a binding contract of sale.
- Whether equitable circumstances barred specific performance.. Specific performance was available because the contract was fair when made and the asserted subsequent circumstances did not establish hardship or injustice sufficient to deny relief. The property's appreciation, Willard's partial assignment, the proposed trust deed's objections, and his tender of United States notes did not defeat his claim.
- What conditions governed the decree of specific performance.. The conveyance had to be ordered conditionally upon Willard's payment of past-due installments and interest in gold and silver coin and his execution of a trust deed securing the remaining installments and interest in like coin.