Lucy V. Zehmer, 196 Va. 493; 84 S.e.2d 516 (1954)

Defendant A.H. Zehmer and his wife owned 471.6 acres of land known as Ferguson Farm in Dinwiddie County, Virginia. Plaintiff W.O. Lucy had known Zehmer for many years and had previously expressed interest in purchasing the farm. On December 20, 1952, Lucy came in to a restaurant owned be the Zehmers with a bottle of whiskey in his hand. Lucy met with Zehmer and while drinking the whiskey discussed the possible sale of the farm. After several on and off discussions about the sale, during which whiskey drinking commenced, Zehmer wrote up an agreement on the back of a restaurant check, simply stating that Zehmer, with his wife as a witness, would sign over Ferguson Farms to Lucy for $50,000. Lucy agreed and signed the document. The next day Lucy spoke to an attorney who validated the agreement and thus Lucy sent word to Zehmer concerning the closing of the sale. Zehmer obviously refuted the agreement and so Lucy was forced to bring an action in a Virginia State court to enforce the agreement which Zehmer argued was invalid due to intoxication.

            The question at hand was whether or not the agreement could be invalidated due to intoxication and the court found the answer to this question to be no. The court found that there was enough evidence to prove that the agreement was valid because of the seriousness and completeness of the transaction. Not only did Zehmer create the document for the agreement, but both he and his wife signed and approved it. Judge Buchanan who wrote for the majority, said the court had found that Zehmer wasn’t intoxicated enough to not comprehend the situation and the agreement and so the agreement was legally binding and thus Zehmer had to accept the sale of his farm. Buchanan also quoted the Restatement of Contracts Clause which said,

“The mental assent of the parties is not requisite for the formation of a contract. If the words or other acts of one of the parties have but one reasonable meaning, his undisclosed intention is immaterial except when an unreasonable meaning which he attaches to his manifestations is known to the other party.”

            I believe that the court made the right decision because from the evidence provided, the agreement was written out, agreed upon and signed by both parties and verified by a witness. Intoxication may have made the verdict somewhat more difficult to find, however Zehmer wouldn’t have been able to complete the agreement had he been too intoxicated. This verdict applies today because it sets a standard for binding contracts and includes involves circumstances that can sway the validity of a contract. All future cases can use this precedent to solve contract conflicts involving intoxication.