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Wood v. Lucy, Lady Duff-Gordon

118 N.E. 214

tl;dr:

A tastemaker granted the plaintiff exclusive authority to lend her endorsement to clothing designs, but then made endorsements without his knowledge. Their contract was enforceable because, although he made no explicit promise, one was fairly implied.

Case Summary

Wood v. Lucy, Lady Duff-Gordon (1917) is a key case in contract law, which introduced the concept of implied terms and consideration. The case involved a famous fashion designer, Lady Duff-Gordon, who signed an exclusive contract with advertising agent Wood to market her designs and endorsements in exchange for a share of the profits. Although the contract did not specifically detail Wood's responsibilities, it granted him sole rights to use Lady Duff-Gordon's endorsements.

Lady Duff-Gordon breached the contract by endorsing products without Wood's permission and keeping all the profits. Wood sued her for damages, claiming she broke their agreement. She argued the contract was invalid due to a lack of consideration, as Wood did not promise to do anything in return for her exclusive rights.

The trial court ruled in Wood's favor, but the appellate court reversed, agreeing with Lady Duff-Gordon. Wood then appealed to the New York Court of Appeals, which reinstated the trial court's decision, holding her accountable to the contract.

Judge Benjamin N. Cardozo argued that though Wood did not promise specific actions, his exclusive rights acceptance implied he would reasonably market Lady Duff-Gordon's products and endorsements. The court also determined Wood's implied promise was enough consideration for Lady Duff-Gordon's exclusive rights grant since it benefited both parties and created a mutual obligation.

This case highlights how courts consider context and circumstances to interpret contracts and imply unstated terms and obligations to uphold the parties' intentions. It also demonstrates contract enforcement even without an express promise as long as some exchanged benefit or detriment exists. This case showcases contract law's adaptability to evolving social and economic environments to provide fair and reasonable outcomes.

ICRAIssue, Conclusion, Rule, Analysis for Wood v. Lucy, Lady Duff-Gordon

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Facts & HoldingWood v. Lucy, Lady Duff-Gordon case brief facts & holding

Facts:Wood (plaintiff) sued Lucy, Lady Duff-Gordon (defendant) for breach of...

Holding:It is true that Wood did not make an explicit...

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Wood v. Lucy, Lady Duff-Gordon

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