Cantu v. Central Education Case Brief PDF

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CANTU v. CENTRAL EDUCATION AGENCY (1994) Plaintiff: Maria Cantu Defendant: San Benito Consolidated Independent School Dist. STATEMENT OF CASE 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. . A question arose as to whether a school district"s acceptance of a resignation letter by mail was effective, if there was no authorization in the resignation letter that the school district"s reponse may be sent by mail. PROCEDURAL HISTORY 1. The State Commissioner of Education ruled that Cantu’s resignation was accepted, and her employment agreement terminated, upon the mailing of the superintendent’s letter accepting the resignation. 2. District court properly concluded that it was reasonable for the school district to accept Cantu"s offer by mail. SUMMARY OF FACTS  Maria Cantu (plaintiff) was under contract to teach special education for the San Benito Consolidated Independent School District (defendant) during the 1990–91 school year. Shortly before the beginning of the school year, on Saturday, August 18, 1990, Cantu hand-delivered a letter of resignation dated August 17 to her supervisor. In it, Cantu requested that her final paycheck be sent to an address 50 miles away.  The superintendent of schools, who was the sole person authorized to accept resignations, received Cantu’s resignation on Monday, August 20.  That same day, he wrote a letter accepting the resignation and deposited it, properly stamped and addressed, in the mail at approximately 5:15 p.m. On Tuesday, August 21, Cantu hand-delivered to the superintendent’s office a letter, which bore a local return address, withdrawing her resignation.  The superintendent then hand-delivered a copy of the letter mailed the previous day, thereby advising Cantu of the acceptance of her resignation and the impossibility of its withdrawal. Cantu filed a claim for breach of her employment agreement. ISSUE What is the proper scope of the "mailbox rule" under Texas law? Was the rule correctly applied by the Commissioner and district court? "Whether authorization to accept by mail may be implied only when the offer is delivered by mail or also when the existing circumstances make it reasonable for the offeree to so accept." HOLDING "[T]he mailbox rule, which makes acceptance effective on dispatch, closes the deal and enables performance more promptly, and places the risk of inconvenience on the party who originally has power to control the manner of acceptance." Whether "the manner of acceptance is reasonable under the circumstances, governs offer and acceptance in commercial transactions under the Texas Business and Commerce Code." • No. The court held that under Texas law, "it is proper to consider whether acceptance by mail is reasonably implied under the circumstances, whether or not the offer was delivered by mail." The court held, "[t]he Commissioner of Education and district court properly concluded that it was reasonable for the school district to accept Cantu"s offer by mail."

• According to the Restatement and Professor Corbin "an acceptance by any medium reasonable under the circumstances is effective on dispatch, absent a contrary indication in the offer." The Restatement also recognizes, "that acceptance by mail is ordinarily reasonable if the parties are negotiating at a distance or even if a written offer is delivered in person to an offeree in the same city." 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  Ac c o r d i n gt ot h ea p p e a l sc ou r t , t h ema i l b o xr u l ep r o v i de dt h a tt hep r op e r l ya d d r e s s e d a c c e p t a n c eo fa no ffe rwa se ffe c t i v ewhe nd e p o s i t e di nt h ema i l , u n l e s so t h e r wi s ea g r e e d orp r o v i de db yl a w.  Th ec o ur ts t a t e dt ha te v e nt h o u g ha no ffe rwa sn o tma d eb yma i la n dt h e r ewa snoe x p r e s s a u t ho r i z a t i on , t hee xi s t i n gc i r c ums t a n c e sma yb es uc ha st oma k ei tr e a s o n a b l ef o rt h e offe r e et oa c c e p tb yma i la n dt ogi v et heo ffe r o rr e a s o nt ok n o wt h a tt h ea c c e p t a n c ewo ul d bes oma d e .  Th ec o ur th e l dt h a ta c c e p t a n c eb yma i lwa si mpl i e d l ya u t h o r i z e di fr e a s on a bl eu n d e rt h e c i r c u ms t a n c e s . 

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