Wucherpfennig v. Dooley

Elizabeth (defendant) offered, by letter to the probate attorney, to sell her farm-inheritance share to her brother Donald (plaintiff) for $200 an acre in a prompt cash deal. The attorney's response said Donald was 'ready to proceed' and had arranged financing, but asked Elizabeth to state the exact dollar amount she expected and whether she'd sign a related valuation agreement — the letter never stated a final price, because, Donald later admitted, $200/acre would total $37,200, an amount he was sure Elizabeth wouldn't accept. Elizabeth then revoked her offer before Donald ever responded with a specific figure. Donald sued for specific performance or partition, arguing the attorney's letter had already accepted her offer.

Whether a valid acceptance of an offer must be unconditional and absolute, without adding or changing the offer's terms or conditions.