New York Court of Appeals

James M. Brown, Charles Congdon and Robert B. Potter, Respondents v. the New York Central Railroad, Appellant

December 28, 187044 N.Y. 79

Summary

The Court of Appeals held that the March correspondence did not constitute an enforceable contract because essential terms were left open for future negotiation, and therefore the plaintiffs were not entitled to rent for April 1858. The judgment awarding rent was reversed and a new trial was ordered. Two concurring opinions agreed with the reversal, emphasizing the need for a written lease and the inchoate nature of the prior negotiations.