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Cantu v. Cent. Educ. Agency - 884 S.W.2d 565 (Tex. App. 1994)

Rule:

The mailbox rule provides that the properly addressed acceptance of an offer is effective when deposited in the mail, unless otherwise agreed or provided by law.

Facts:

Plaintiff Maria Diosel Cantu was hired as a special-education teacher by defendant San Benito Consolidated Independent School District ("District") under a one-year contract for the 1990-91 school year. On Saturday, Aug. 18, 1990, shortly before the start of the school year, Cantu hand-delivered to her supervisor a letter of resignation, effective Aug. 17, 1990; the letter requested that her final paycheck be forwarded to an address located some 50 miles away from San Benito. The District's superintendent of schools, the only official authorized to accept resignations on behalf of the District, received Cantu's resignation on Monday, Aug. 20. The superintendent wrote a letter accepting Cantu's resignation the same day and deposited the letter, properly stamped and addressed, in the mail at approximately 5:15 p.m. that afternoon. At about 8:00 a.m. the next morning, Aug. 21, Cantu hand-delivered to the superintendent's office a letter withdrawing her resignation; the letter had a San Benito return address. In response, the superintendent hand-delivered that same day a copy of his letter mailed the previous day to inform Cantu that her resignation had been accepted and could not be withdrawn. The Texas State Commissioner of Education concluded that because the District's acceptance of Cantu's resignation was effective when mailed, an agreement to rescind Cantu's employment contract was in force when she attempted to withdraw her offer of resignation and the District's refusal to honor her contract was not unlawful. Cantu appealed that decision to Texas district court, which affirmed the Commissioner's decision. Cantu appealed.

Issue:

Was Cantu's contract of employment rescinded when the letter accepting Cantu's resignation was placed in the mail?

Answer:

Yes.

Conclusion:

The court affirmed the trial court's judgment finding the District's acceptance by mail of Cantu's letter of resignation was valid under the circumstances. The court noted that 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 further noted that even though an offer was not made by mail and there was no express authorization, the existing circumstances could 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 ruled that it was reasonable for the superintendent to accept Cantu's offer of resignation by mail given the facts that: (1) Cantu tendered her resignation shortly before the start of the school year, and on a Saturday, making it nearly impossible for the superintendent to receive or respond to her offer, and; (2) Cantu's request that her final paycheck be forwarded to a distant address, indicating that she would not be available locally.

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