Beall v. Beall
Court of Special Appeals of Maryland
413 A.2d 1365 (1980)
Carlton Beall (plaintiff) bought a farm bordering property owned by his cousin Calvin and Calvin's wife Cecilia Beall (defendant). As part of the farm purchase, Carlton got a three-year option to buy the Calvin/Cecilia property for $28,000, paid for with $100 in consideration. Carlton let that option lapse, and the parties later signed a new five-year option, again for $100 in consideration. In 1975, the parties extended that option three more years, to February 1979, but this extension included no new consideration. After Calvin died, Cecilia inherited the property outright. When Carlton tried to exercise the option in 1978, Cecilia refused to sell, and Carlton sued for specific performance. The trial court sided with Cecilia, holding the extension failed for lack of consideration. Carlton appealed.
Whether an optionee who exercises an unsupported (no-consideration) option before it is revoked or expires can force the optionor to specifically perform the sale.