Cantu v. Central Education Agency
884 S.W.2d 565 (1994)
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Rule of Law:
An acceptance of an offer is effective upon dispatch (the "mailbox rule") when it is sent by a medium that is reasonable under the circumstances, even if the offer was delivered in person and did not expressly authorize acceptance by mail.
Facts:
- Maria Diosel Cantu was a special-education teacher for the San Benito Consolidated Independent School District under a one-year contract for the 1990-91 school year.
- On Saturday, August 18, 1990, just before the school year began, Cantu hand-delivered a letter of resignation to her supervisor.
- In her resignation letter, Cantu requested that her final paycheck be mailed to an address in McAllen, Texas, about fifty miles away from San Benito.
- On Monday, August 20, the school superintendent, the only official who could accept resignations, received the letter.
- At approximately 5:15 p.m. on August 20, the superintendent deposited a letter in the mail accepting Cantu's resignation.
- At about 8:00 a.m. the next morning, August 21, Cantu hand-delivered a letter to the superintendent's office attempting to withdraw her resignation.
Procedural Posture:
- Maria Diosel Cantu's resignation was accepted by the San Benito Consolidated Independent School District.
- The State Commissioner of Education, Lionel Meno, issued a final order concluding that the school district's acceptance was effective when mailed, creating a binding agreement to rescind the employment contract.
- Cantu sued for judicial review of the Commissioner's order in the district court.
- The district court affirmed the Commissioner's decision.
- Cantu (appellant) appealed the district court's judgment to the Court of Appeals of Texas, Third District, at Austin.
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Issue:
Does the mailbox rule apply to make an acceptance effective upon mailing when the offer was delivered in person, but the surrounding circumstances made it reasonable for the offeree to accept by mail?
Opinions:
Majority - Bea Ann Smith
Yes, the mailbox rule applies to make an acceptance effective upon mailing when the circumstances make it reasonable for the offeree to accept by mail, regardless of how the offer was delivered. The court held that the rule allowing acceptance by any medium reasonable under the circumstances is the modern and correct approach. The court distinguished older precedent suggesting acceptance by mail is only authorized if the offer was made by mail, aligning Texas law with the Restatement (Second) of Contracts and the Texas Business and Commerce Code. The court found it was reasonable for the superintendent to accept by mail because Cantu resigned right before the school year, necessitating a quick response to find a replacement, and provided an out-of-town address, indicating she did not intend to return to the school and could not be reached in person.
Analysis:
This decision modernizes the application of the mailbox rule in Texas by shifting the focus from a rigid, formalistic inquiry (was the offer made by mail?) to a more flexible, context-based standard of reasonableness. It aligns Texas contract law with the Restatement (Second) of Contracts and the Uniform Commercial Code, promoting consistency across different areas of law. The ruling clarifies that an offeror does not need to use the mail to create an implied authorization for the offeree to accept by mail; instead, the overall circumstances dictate whether mailing an acceptance is a reasonable method of contract formation.
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