New York Court of Appeals

Charles H. Southard, Appellant v. John J. Curley, Respondents

June 7, 1892134 N.Y. 148

Summary

The Court affirmed the lower court, holding that in a contract reformation action the burden of proof rests on the party alleging mistake and is satisfied by a preponderance of evidence, not the criminal standard of beyond a reasonable doubt; consequently the trial court did not err in refusing to direct a verdict or to give a criminal‑standard jury instruction.