Tennessee Supreme Court - 824 S.W.2d 545
In Dodson v. Shrader (1992), the Supreme Court of Tennessee addressed a case involving minors' contractual rights and responsibilities. The case concerned Joseph Dodson, a 16-year-old who bought a truck from Shrader's Auto Sales for $4,900. After the truck broke down, Dodson sought to rescind the contract, claiming he lacked legal capacity as a minor. Shrader refused a refund, leading to Dodson suing for rescission.
The trial court granted Dodson's request, ordering Shrader to repay the full purchase price. Shrader appealed, asserting the right to deduct compensation for the truck's use, depreciation, and damage while in Dodson's possession.
The Supreme Court sided with Shrader, reversing the trial court's decision and adopting a new rule allowing sellers to recover reasonable compensation from minors seeking contract rescission, except in cases of overreaching, fraud, or unfair advantage. The court reasoned that this balanced both parties' interests and reflected the evolving social and economic realities of minors in modern society.
This case is significant because it altered Tennessee's common law doctrine of infancy, creating a more equitable approach to contracts with minors. It also influenced other states to adopt similar rules or statutes modifying the traditional full restitution rule for minors who disaffirm contracts. Furthermore, the case demonstrates how courts can adapt the law to changing circumstances when the legislature fails to act.
The case involves a minor who purchased a used pick-up truck that developed mechanical problems and the engine failed nine months after the purchase. The circuit court granted the rescission and ordered the seller to reimburse the purchase price upon tender and delivery of the truck. The Court of Appeals affirmed the decision based on the rule established in Wheaton v. East in 1833, which states that contracts that are to the detriment of the minor are void, contracts for necessities are valid, and contracts of uncertain nature are voidable at the minor's discretion. The modern rule in Tuck v. Payne favors contracts of minors as voidable and not void, allowing them to invoke advantageous contracts and avoid injudicious ones. The Benefit Rule has emerged as a minority rule, allowing the other party to a contract with a minor to deduct the value of the minor's use of the merchandise from the full purchase price upon rescission. The court believes that a modified version of the Oregon rule should be adopted in Tennessee regarding the rights and responsibilities of minors in their business dealings. The rule in cases involving contracts of minors is that if the minor has not been overreached or unduly influenced, and the contract is fair and reasonable, and the minor has actually paid money and used the purchased item, then the minor cannot recover the amount paid without allowing the seller reasonable compensation for use, depreciation, and damage to the item. The fair market value of the property returned and whether there has been overreaching is a question for the trier of fact. The lower court did not err in granting the rescission and ordering the reimbursement of the purchase price.
LSD+ gives you access to over 50,000 case briefs, more than anyone else. Be the first to email us the website of a case brief product that offers you more case briefs and we'll give you a free year of LSD+.
Unlimited access. Read as much content as you want during your trial with no device limitations. Cancel any time during your trial and keep access for the full 14 days.
Lawyers and judges love to use big words. And Latin, for some reason.
Highlight a legal term in LSD Briefs and get an instant, plain English definition. Try highlighting contract or specific performance. No need to search or read through a list of definitions, simply highlight the words you don’t know and our LSDefine integration will instantly give you a definition to any of over 30,000 legal terms.
DeepDive allows you to explore legal cases like never before. DeepDive offers multiple levels of case summaries, which empowers you to quickly and easily find the information you need to stay on top of readings. Easily navigate through summary levels and click on any text to get more detail, all the way down to the original legal case text.
Our proprietary state-of-the-art system can instantly brief over 6,000,000 US cases. That means we can probably brief that case that your professor assigned last night when she sent you a poorly scanned pdf and told you to read every third paragraph. Or maybe she uploaded it to Canvas and didn’t really tell you to read it, but you know you probably should. Tenure does wild things to good people.
Study groups are a great way to learn and explore a case. LSD has chat rooms for each case to let you ask questions across the community and hear what other students struggled with and how they put it all together. Learn the key points of every case from other LSD+ users and share your knowledge with LSD High Points.
Don’t settle for mistakes in briefs that have been there for 10 years and never fixed. Find an issue or something missing from a brief? Down vote and we will make improvements. All of our case brief editors graduated from from T14 law schools.