No. The contract is still valid. The court said it's your responsibility to read what you sign. Not understanding it is your own mistake, not the store's fault, as long as they didn't lie to you. The court also said that while the store's behavior was terrible ('sharp practice'), there was no law in D.C. that made this kind of contract illegal. The judges felt the deal was exploitative but said it was up to lawmakers, not the court, to pass new laws to protect people from such unfair contracts.

No, the woman still has to follow the contracts even though she didn't understand them and the store knew she was struggling financially. She had a responsibility to read and understand the contracts before signing. Her mistake in not doing so doesn't allow her to ignore the contracts unless the store tricked her, which they didn't.

The court thinks the store acted badly and took advantage of the woman's situation, but the law doesn't let the court cancel the contracts for being unfair. I point out that if D.C. had laws like Maryland's that protect people from this kind of thing, we could help the woman. I think lawmakers should make laws to stop stores from using contracts like these that are bad for struggling people.

Since the woman has to follow the contracts even though she didn't understand them, and since the law doesn't make the contracts invalid for being unfair, the court has to agree with the store and say the contracts are still in effect.

<opinion type="majority"> <author id="b951-14">QUINN, Associate Judge.</author> Appellant, a person of limited education separated from her husband, is maintaining herself and her seven children by means of public assistance. During the period 1957-1962 she had a continuous course of dealings with appellee from which she purchased many household articles on the installment plan. These included sheets, curtains, rugs, chairs, a chest of drawers, beds, mattresses, a washing machine, and a stereo set. In 1963 appellee filed a complaint in replevin for possession of all the items purchased by appellant, alleging that her payments were in default and that it retained title to the goods according to the sales contracts. By the writ of replevin appellee obtained a bed, chest of drawers, washing machine, and the stereo set. After hearing testimony and examining the contracts, the trial court entered judgment for appellee. Appellant’s principal contentions on appeal are (1) there was a lack of meeting of the minds, and (2) the contracts were against public policy. Appellant signed fourteen contracts in all. They were approximately six inches in length and each contained a long paragraph in extremely fine print. One of the sentences in this paragraph provided that payments, after the first purchase, were to be prorated on all purchases then outstanding. Mathematically, this had the effect of keeping a balance due on all items until the time balance was completely eliminated. It meant that title to the first purchase, remained in appellee until the fourteenth purchase, made some five years later, was fully paid. At trial appellant testified that she understood the agreements to mean that when payments on the running account were sufficient to balance the amount due on an individual item, the item became hers. She testified that most of the purchases were made at her home; that the contracts were signed in blank; that she did not read the instruments; and that she was not provided with a copy. She admitted, however, that she did not ask anyone to read or explain the contracts to her. <page-number citation-index="1" label="916">*916</page-number>We have stated that “one who refrains from reading a contract and in conscious ignorance of its terms voluntarily assents thereto will not be relieved from his bad bargain.” Bob Wilson, Inc. v. Swann, D.C.Mun.App., 168 A.2d 198, 199 (1961). “One who signs a contract has a duty to read it and is obligated according to its terms.” Hollywood Credit Clothing Co. v. Gibson, D.C.App., 188 A.2d 348, 349 (1963). “It is as much the duty of a person who cannot read the language in which a contract is written to have someone read it to him before he signs it, as it is the duty of one who can read to peruse it himself before signing it.” Stern v. Moneyweight Scale Co., 42 App.D.C. 162, 165 (1914). A careful review of the record shows that appellant’s assent was not obtained “by fraud or even misrepresentation falling short of fraud.” Hollywood Credit Clothing Co. v. Gibson, supra. This is not a case of mutual misunderstanding but a unilateral mistake. Under these circumstances, appellant’s first contention is without merit. Appellant’s second argument presents a more serious question. The record reveals that prior to the last purchase appellant had reduced the balance in her account to $164. The last purchase, a stereo set, raised the balance due to $678. Significantly, at the time of this and the preceding purchases, appellee was aware of appellant’s financial position. The reverse side of the stereo contract listed the name of appellant’s social worker and her $218 monthly stipend from the government. Nevertheless, with full knowledge that appellant had to feed, clothe and support both herself and seven children on this amount, appellee sold her a $514 stereo set. We cannot condemn too strongly appellee’s conduct. It raises serious questions of sharp practice and irresponsible business dealings. A review of the legislation in the District of Columbia affecting retail sales and the pertinent decisions of the highest court in this jurisdiction disclose, however, no ground upon which this court can declare the contracts in question contrary to public policy. We note that were the Maryland Retail Installment Sales Act, Art. 83 §§ 128-153, or its equivalent, in force in the District of Columbia, we could grant appellant appropriate relief. We think Congress should consider corrective legislation to protect the public from such exploitive contracts as were utilized in the case at bar. Affirmed. </opinion>

—the District of Columbia Court of Appeals explained its rejection of this contention as follows: "Appellant's second argument presents a more serious question. The record reveals that prior to the last purchase appellant had reduced the balance in her account to $164. The last purchase, a stereo set, raised the balance due to $678. Significantly, at the time of this and the …

'We think Congress should consider corrective legislation to protect the public from such exploitive contracts as were utilized in the case at bar.'

The District of Columbia Court of Appeals determined that Williams' consent was not obtained by fraud or misrepresentation

Walker-Thomas attempted to enforce the installment provision allowing it to repossess all the goods previously purchased by Williams. Was this contract enforceable

The court below noted that the debtor Williams was "a person of limited education separated from her husband [,] maintaining herself and her seven children by means of public assistance."

—knowledge that appellant had to feed, clothe and support both herself and seven children on this amount, appellee sold her a $514 stereo set

We have stated that one who refrains from reading a contract and in conscious ignorance of its terms voluntarily assents thereto will not be relieved from his bad bargain

—at 449 n. 6 (Henningsen as source of "absence of meaningful choice" and "terms unreasonably favorable" two-part test), at 449 n. 7 (Supporting requirement of "gross disparity in bargaining power"), and at 450 n. 12 (Supporting requirement that terms must be "so extreme as to appear unconscionable"). 197.

No. The installment contracts are enforceable. A party who signs a contract without reading it is bound by its terms unless their assent was obtained by fraud or misrepresentation. The court rejected the consumer’s argument about a lack of 'meeting of the minds,' characterizing her failure to read or understand the contract as a 'unilateral mistake' from which she could not be relieved. Regarding the public policy argument, the court, while strongly condemning the seller's 'sharp practice' and 'exploitive' conduct, found no basis in D.C. legislation or controlling case law to declare the contracts unenforceable. The court concluded that providing relief from such contracts was a matter for Congress, not the judiciary.

No, the contracts are enforceable despite appellant's lack of understanding and the appellee's knowledge of her poor financial situation. Appellant had a duty to read and understand the contracts before signing them. Her failure to do so constitutes a unilateral mistake, not warranting relief absent evidence of fraud or misrepresentation by appellee. 

While the court strongly condemns appellee's irresponsible and exploitative business practices, especially given their awareness of appellant's financial hardships, there are no legal grounds under current D.C. law to invalidate the contracts as against public policy. I note that if legislation similar to Maryland's Retail Installment Sales Act were in effect in D.C., relief could be granted. I urge Congress to consider enacting consumer protections against such predatory contracts. 

Because appellant is bound by the contracts she signed despite her unilateral mistake and lack of understanding, and because no public policy grounds exist to negate the contracts' enforceability, the trial court's judgment for appellee is affirmed.

Williams v. Walker-Thomas Furniture Co.

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