Frank S. Oakes, Appellant v. the Cattaraugus Water Company, Respondent

Summary

The New York Court of Appeals reversed the lower court's dismissal and ordered a new trial, holding that the corporation could be bound by the pre‑incorporation contract if its president ratified it, and that the contract was not void on public‑policy grounds. The court emphasized that whether ratification occurred is a factual issue for the jury. Justice Gray dissented, arguing that no ratification was possible because no corporation existed to be the principal.