Hendricks v. Behee

Behee offered to buy real estate from the Smiths through their agent. The agent mailed the offer to the Smiths, who signed and accepted it, but that acceptance was never communicated to Behee. Before it could be, Behee contacted the agent and withdrew his offer. Hendricks (plaintiff), holding Behee's $5,000 earnest-money deposit, interpleaded to resolve the dispute over whether a binding contract existed.

Whether an offeror may revoke an offer before the offeree's acceptance is communicated to the offeror or the offeror's agent.