Brackenbury v. Hodgkin
116 Me. 399 (1917)
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Rule of Law:
An offer for a unilateral contract becomes a binding promise and cannot be revoked once the offeree has begun performance of the requested act. When such a contract concerns land, the performing party acquires an equitable interest in the property that can be protected by a court of equity.
Facts:
- Sarah D. P. Hodgkin, a widow, lived alone on her home farm in Lewiston, Maine.
- On February 8, 1915, Hodgkin sent a letter to her daughter and son-in-law, the Brackenburys, who were residing in Missouri.
- The letter proposed that if the Brackenburys moved to Maine, cared for Hodgkin on the farm for the rest of her life, and paid their moving expenses, they would receive the use of the property and would own it after her death.
- In reliance on this offer, the Brackenburys moved from Missouri to the farm in late April 1915 and began performing their contractual duties.
- After a few weeks, relations deteriorated, and Hodgkin ordered the Brackenburys to leave the property, but they refused.
- On November 7, 1916, Hodgkin conveyed the farm to her son, Walter Hodgkin, reserving a life estate for herself.
- Walter took the deed with full knowledge of the agreement between his mother and the Brackenburys, for the sole purpose of evicting them.
Procedural Posture:
- After disputes arose, Mrs. Hodgkin brought two minor lawsuits against her son-in-law.
- After deeding the property to her son Walter, Walter served a notice to quit upon the Brackenburys and subsequently brought an action of forcible entry and detainer against them.
- The Brackenburys (plaintiffs) filed a bill in equity in a trial court against Mrs. Hodgkin and Walter Hodgkin (defendants).
- The trial court (the sitting Justice) issued a decree in favor of the plaintiffs, granting the equitable relief they requested.
- The defendants, Mrs. Hodgkin and Walter Hodgkin, appealed the trial court's decree to the Law Court of Maine, the state's highest court of appeals.
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Issue:
Does an offer for a unilateral contract become an irrevocable, binding promise once the offeree has started to perform the requested acts, thereby creating an enforceable equitable interest in the land that is the subject of the contract?
Opinions:
Majority - Cornish, C. J.
Yes. An offer for a unilateral contract becomes an irrevocable promise once performance has begun. The mother's letter was an offer for a unilateral contract, which seeks performance of an act rather than a return promise. The Brackenburys accepted this offer not with words, but by the act of moving from Missouri to Maine and commencing their care for Mrs. Hodgkin. Once they began performance, the mother's offer became a binding and irrevocable promise. This performance, coupled with the written offer, created an equitable interest in the land in favor of the Brackenburys. The court found that Mrs. Hodgkin was the 'provoking cause' of the family difficulties, so the Brackenburys had not failed in their performance. Therefore, they are entitled to equitable relief, including an order establishing that the mother holds the property in trust for them, subject to their continued performance.
Analysis:
This case is a classic illustration of the legal principles governing unilateral contracts, solidifying the modern rule that part performance makes an offer irrevocable. It prevents an offeror from revoking an offer after inducing an offeree to begin performance, thereby avoiding an unjust outcome. The decision also demonstrates the power of equity to enforce such agreements when land is involved by imposing a constructive trust, ensuring that a party who has substantially relied on a promise is protected. This precedent is crucial for understanding how acceptance by performance works and the limits on an offeror's power of revocation.
