What is the main rule from Lucy v. Zehmer?

Courts use the objective test. If a reasonable person would think you intended a contract from your words and actions, a contract exists.

Can ‘I was joking’ defeat a contract claim?

No, not if your outward words and acts show a serious deal. Private jokes do not cancel clear, serious-looking promises.

Was intoxication a defense here?

No. The court found the defendant was not too drunk to understand. He discussed terms and wrote and signed the agreement.

What remedy did the court grant?

Specific performance. The seller had to go through with the land sale because a valid contract existed.

Why is Lucy v. Zehmer important for exams?

It proves intent is measured objectively, not by secret thoughts. Use it when someone claims the deal was a joke.

lucy-v-zehmer-objective-intent-contract

Lucy v. Zehmer (Objective Intent in Contract)

Contract Law Supreme Court of Virginia 1954 Citation: 84 S.E.2d 516 Bench: Supreme Court Reading time: ~4–5 min

Author: Gulzar Hashmi | India | Published on 26 Oct 2025

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Quick Summary

A landowner wrote and signed a note to sell his farm for $50,000 and got his wife to sign too. He later said it was a joke and that he was drunk. The court said: what matters is the objective look of words and actions. Here they looked serious, so there was a valid contract. The buyer got specific performance.

Issues

Does a valid contract exist between the parties?
Can a party avoid the deal by saying “I was joking” or “I was drunk”?

Rules

Objective intent test: Would a reasonable person think there was an intention to contract?
Secret jokes or hidden thoughts do not defeat a contract when outward acts show assent.
Mere drinking is not enough; incapacity requires proof of not understanding the transaction.

Exam Tip: “Objective intent beats secret intent.” Quote this when a party pleads “just kidding.”

Facts (Timeline)

Timeline visual for Lucy v. Zehmer facts

Written note: Husband wrote and signed a promise to sell his farm for $50,000; got his wife to sign.

Consideration step: Buyer paid $5 to hold the bargain.

Witness: A waitress later said the husband was joking.

Buyer’s readiness: Buyer arranged funds with his brother for half the price.

Refusal: Seller later refused to convey, claiming joke and intoxication.

Sued: Buyer filed for specific performance.

Arguments

Appellant/Plaintiff (Lucy)

Written, signed agreement + discussion of terms = objective intent.
Ability and readiness to pay shown; asked for specific performance.

Respondent/Defendants (Zehmers)

It was a joke; no real intent to sell.
Husband was too drunk; lacked capacity to contract.

Judgment (Held)

The court held that a valid contract existed. The husband was not too drunk to understand, and the outward words and actions showed a serious bargain. “Joking” is not a defense when a reasonable person would read the conduct as real.

Contract enforced.
Remedy: Specific performance of the land sale.

Ratio Decidendi

Intent is judged objectively. If your words and actions would make a reasonable person think you assented, then a contract exists, even if you secretly did not mean it.

Why It Matters

Protects reliance on clear, serious-looking offers and acceptances.
Stops parties from escaping with “I was joking” after signing.
Shows why land deals often lead to specific performance.

Key Takeaways

Objective intent > secret intent.
Writing + signatures + terms = strong proof of assent.
Intoxication needs real proof of incapacity, not just drinking.

Mnemonic + 3-Step Hook

Mnemonic: “LOOK = Looks Over Own Knowledge”

Looks at words and acts.
Overrides hidden jokes.
Own Knowledge of secret intent does not matter.

3-Step Exam Hook

List the outward facts: writing, signatures, terms.
Apply the reasonable person test.
Address defenses: joke/intoxication → insufficient.

IRAC Outline

Issue

Did the parties form a valid contract despite a later claim of joking and intoxication?

Rule

Objective intent governs: reasonable person standard; specific performance available for land.

Application

Written, signed note with price and property; discussion of terms; buyer arranged funds; conduct looked serious.

Conclusion

Valid contract; specific performance ordered.

Glossary

Objective Intent: Legal test that looks at outward words and actions, not secret thoughts.
Specific Performance: Court order to perform the contract, common in land sale cases.
Capacity: Ability to understand the nature and consequences of the transaction.