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Laidlaw v. Organ - 15 U.S. (2 Wheat.) 178 (1817)

Rule:

The vendee is not bound to communicate to the vendor of goods the intelligence of extrinsic circumstances, which might influence the price of the commodity, and which is exclusively within the knowledge of the vendee, particularly where the means of intelligence are equally accessible to both parties.

Facts:

In 1815, buyer Organ purchased 111 hogsheads of tobacco and that the same were delivered to him by the sellers. However, two days later, the buyer alleged that the sellers by force took possession of the tobacco, and unlawfully withheld the same from the buyer, notwithstanding he was at all times ready to do and perform all things on his part stipulated to be done in their bill of exchange. Thus, the buyer filed a case against the sellers. 

Issue:

Is a vendee is bound to communicate to the vendor of goods the intelligence of extrinsic circumstances, which might influence the price of the commodity, and which is exclusively within the knowledge of the vendee?

Answer:

No

Conclusion:

The Supreme Court of the United States ruled that a vendee is not bound to communicate to the vendor of goods the intelligence of extrinsic circumstances, which might influence the price of the commodity, and which is exclusively within the knowledge of the vendee, particularly where the means of intelligence are equally accessible to both parties. The Court found that Organ, as the purchaser, was not bound to communicate news of a peace treaty. The judgment was reversed and the cause remanded to the District Court of Louisiana, with directions to award a venire facias de novo.

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