Babcock v. Engel

Facts: While Charles Engel's wife was out of town, he sat home alone, drinking mightily. During this period, he made an agreement with G. M. Babcock to trade a 320 acre farm and $2000 worth of personal property for a hotel. Engel's property was worth approximately twice the value of the hotel. Engel later refused to honor the deal on the grounds that he had been intoxicated when he made the agreement. Babcock sued, but the jury sided with Engel and dismissed the complaint. Babcock appealed.

What is the issue in this case?

What is the rule of law in this case? Remember, the rule of law is the legal principle the court relies upon to resolve the issue.

Which specific element of the rule is in question in this case?

Next, read the Holding of the case below, then complete the exercise that follows.

Excerpts from Justice Holloway's Decision: If, as a matter of fact, Engel was so far under the influence of intoxicating liquor when he signed the contract that he was incapable of giving his assent it would be voidable at the election of Engel when he became sober.[T]he jury answered that on November 22, Engel was "so under the influence of intoxicating liquors as to deprive him of his powers of reasoning and render him unable to comprehend the consequences of his act in executing said agreement."

Engel himself testified to the effect that, availing himself of his wife's absence from home, he had been indulging greatly to excess and had been drunk on November 21; that he drank heavily of whisky which he had at his home on the morning of November 22; that immediately upon his arrival in the town he had four or five drinks of whisky and blackberry before he entered upon the negotiations with Babcock. Upon the question of his intoxication he was corroborated abundantly.

Four other witnesses, each apparently disinterested, testified that at the time in question Engel was intoxicated, could not comprehend the nature of his acts, in other words, that he was not qualified to transact business. The jury determined upon the credibility of the witnesses.

Intoxication is not made a defense by the Codes, and there was a time in the history of our jurisprudence when courts refused to lend their aid to relieve one from the consequences of his own voluntary intemperance, but the doctrine has long since been abandoned. The courts do not now concern themselves so much with the question of intoxication as with the question of contractual capacity, and if in fact either party is not mentally capable of giving his free consent to the terms disclosed by the writing, it is altogether immaterial by what cause his incapacity was produced. The courts have simply recognized the fact that intoxication, among other things, may render a person incapable of making a binding contract.

The test approved by the great majority of the decisions is the same which is applied in other forms of mental derangement, namely, that the deed or contract will be voidable if the person, at the time of its execution, was so far under the influence of intoxicants as to be unable to understand the nature and consequences of his act, and unable to bring to bear upon the business in hand any degree of intelligent choice and purpose. Affirmed.

1. Underline the text that illustrates the rule of law in this case.

2. Highlight the text that illustrates the court's analysis of the case in a color of your choice.

3. What was the court's conclusion in this case? Explain your conclusion.