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Dodson v. Shrader

(1992)

Tennessee Supreme Court - 824 S.W.2d 545

tl;dr:

A minor purchased a car without misrepresenting his age. But then the car broke down and he invoked the infancy doctrine to try and get his money back. Defendant refused to accept the broken-down car and did not refund the infant.

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Case Summary

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.

ICRAIssue, Conclusion, Rule, Analysis for Dodson v. Shrader

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Facts & HoldingDodson v. Shrader case brief facts & holding

Facts:Plaintiff Dodson, a minor, purchased a pickup truck from Defendant...

Holding:Remanded. If there was no overreach or undue influence of...

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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.

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