Laidlaw v. Organ

Organ (plaintiff) was buying tobacco from Laidlaw (defendant), and just before the sale closed, Laidlaw asked Organ whether he knew of any reason the tobacco's market price might suddenly change; Organ said no, even though he actually knew the War of 1812 had just ended, a fact that nearly doubled tobacco's market value, while Laidlaw remained unaware of it. After the sale closed and the tobacco was delivered, Laidlaw learned of the war's end and took the tobacco back from Organ, prompting Organ to sue. The trial court granted Organ a directed verdict, instructing the jury that Organ had said nothing 'calculated to impose upon' Laidlaw regarding the war news, and Laidlaw appealed that instruction as improperly taking the factual question away from the jury.