Wednesday, December 11, 2013

Cantu v. Central Education Agency case brief

Cantu v. Central Education Agency case brief summary
884 S.W.2d 565 (1994)


CASE SYNOPSIS
Appellant teacher challenged an order from the District Court of Travis County, 331st Judicial District (Texas), where appellee commissioner of education's finding that school's acceptance by mail of appellant's letter of resignation was affirmed.

CASE FACTS
Appellant teacher resigned her position as special education teacher and hand-delivered a letter of resignation. Appellant's letter was received and was accepted. Appellant later sought to withdraw her resignation and brought suit asserting that her letter of resignation could not be accepted by mail because it was not delivered by mail and there was no express authority to accept by mail. Appellee commissioner of education and the trial court found that the acceptance was valid.

DISCUSSION

  • The appeals court affirmed the judgment. 
  • According to the appeals court, the mailbox rule provided that the properly addressed acceptance of an offer was effective when deposited in the mail, unless otherwise agreed or provided by law. 
  • The court stated that even though an offer was not made by mail and there was no express authorization, the existing circumstances may be such as to make it reasonable for the offeree to accept by mail and to give the offeror reason to know that the acceptance would be so made. 
  • The court held that acceptance by mail was impliedly authorized if reasonable under the circumstances. 
  • The court found that the acceptance by mail was proper given the circumstances.

CONCLUSION
The appeals court affirmed the judgment finding the school's acceptance by mail of appellant teacher's letter of resignation was valid under the circumstances. The court held that although the offer was not made by mail and there was no express authorization to accept by mail, acceptance by mail was proper because it was reasonable for appellant to expect an acceptance by mail.


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