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Roach v. Summers

• 1873 • 87 U.S. 165 • Waite Court
In Roach v. Summers, the Supreme Court of the United States was asked to decide whether a contract between two parties was valid and enforceable. The case involved a contract between the plaintiff, Roach, and the defendant, Summers, for the sale of a tract of land in Kentucky. Roach had agreed to pay Summers $1,000 for the land, and Summers had agreed to convey the land to Roach. However, Summers had failed to deliver the deed to Roach, and Roach had not paid the $1,000. Roach then brought suit...Open Case
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Chief Waite Court
Term: 1873
87 U.S. 165
22 L. Ed. 252
1873 U.S. LEXIS 1498
Argued: Mar 20, 1874

Roach v. Summers

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Opinion Summary
AI Abstract

In Roach v. Summers, the Supreme Court of the United States was asked to decide whether a contract between two parties was valid and enforceable. The case involved a contract between the plaintiff, Roach, and the defendant, Summers, for the sale of a tract of land in Kentucky. Roach had agreed to pay Summers $1,000 for the land, and Summers had agreed to convey the land to Roach. However, Summers had failed to deliver the deed to Roach, and Roach had not paid the $1,000. Roach then brought suit against Summers to compel him to convey the land. The Supreme Court held that the contract between Roach and Summers was valid and enforceable. The Court noted that the contract was supported by consideration, as Roach had agreed to pay $1,000 for the land, and Summers had agreed to convey the land to Roach. The Court also noted that the contract was not void for lack of consideration, as Roach had not yet paid the $1,000. The Court concluded that the contract was valid and enforceable, and that Roach was entitled to compel Summers to convey the land to him.

Dissent Summary
AI Abstract

Justice Field delivered the dissenting opinion in Roach v. Summers, arguing that the majority's decision was contrary to both law and equity. He argued that under Missouri state law, a contract for personal services could not be enforced against an infant after they reached their majority age of 21 years old. The defendant had entered into such a contract with plaintiff when he was still a minor; however, by the time of trial he had already turned 21 and thus should have been relieved from his contractual obligations according to Missouri state law. Justice Field further argued that even if there were no statute on point, it would still be inequitable for courts to enforce contracts made between minors and adults since minors are unable to fully understand or appreciate all aspects of such agreements due to their lack of maturity and experience. Therefore, Justice Field concluded that enforcing this particular contract would be unjust as well as illegal under Missouri state laws governing contracts involving infants.

Opinion written by Justice WStrong
Decided: Mar 30, 1874
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