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Wisconsin Supreme Court - 64 Wis. 265
In 1885, the Wood v. Boynton case in the Wisconsin Supreme Court tackled a significant issue about the mutual mistake principle in contract law. The case set a legal precedent for mutual mistake and clarified when a contract could be canceled because of a mutual mistake of fact.
Wood sold Boynton a small stone, thinking it was a common quartz. They agreed on a price, and Boynton took the stone. Later, they found out it was an uncut diamond worth much more. Wood sued Boynton, aiming to cancel the contract and get the diamond back, claiming a mutual mistake.
The trial court sided with Boynton, and Wood appealed, arguing that the mutual mistake about the stone's real identity should make the contract voidable.
The Wisconsin Supreme Court maintained the trial court's decision, ruling that the contract couldn't be canceled because of a mutual mistake. The court explained that a mutual mistake could only justify canceling a contract if the mistake involves a material fact crucial to the contract. In this case, the true nature of the stone wasn't a vital fact to the contract, as both parties thought they were making a valid agreement for a quartz piece. The court also pointed out that both parties assumed the risk of the stone being different from their belief.
The Wood v. Boynton case is essential because it clarified mutual mistake and set a precedent for when a contract can be canceled due to a mutual mistake of fact. This decision guided courts and parties in contract disputes, ensuring that contracts would only be canceled when the mutual mistake concerns a crucial material fact in the contract.
The plaintiff sold an uncut diamond to one of the defendants for one dollar, unaware of its true value. After discovering its value, the plaintiff offered to return the dollar and demanded the diamond's return, but the defendants refused. The plaintiff sought to recover the diamond in this action. The plaintiff can only maintain her action if she can rescind the sale and revest the title in herself. This can only be done if the vendee committed fraud or if there was a mistake in the identity of the thing sold. If the thing delivered was not the thing sold, then no title ever passed to the vendee. The circuit judge erred in directing the jury to find a verdict for the defendants.
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