Monday, November 11, 2013

Beall v. Beall case brief

Beall v. Beall case brief summary
413 A.2d 1365 (1980)

Plaintiff prospective land buyer appealed an order of the Circuit Court for Prince George's County, which granted defendant landowner's motion dismissing the buyer's complaint. The buyer sought specific performance of an option agreement to purchase land.


  • The landowner owned the parcel that bordered on three sides of a farm that the buyer had purchased. 
  • The same day he contracted to buy the farm, the buyer obtained a three-year option to purchase the landowner's parcel, for which he paid a money consideration. 
  • The option was never exercised, and the parties executed a new option for five years and for an additional consideration. 
  • The later option was never exercised, but language was appended to the agreement extending the option for three more years. 
  • When the buyer attempted to exercise the option, the landowner had died, and the trial court found that there was no consideration for the extension because no benefit flowed to the landowner's widow.

The court held that under Maryland law, an option unsupported by consideration was no longer irrevocable but became a mere offer to sell which the optionor could withdraw at any time before acceptance. The court held that the trial court erred in failing to determine whether or not there was a valid, unrevoked offer to sell the property and whether or not there was proper acceptance of the offer sufficient to create a contract specifically enforceable in equity.


The court reversed the order of the trial court and remanded the cause for a new trial in accordance with the court's opinion.

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