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Stees v. Leonard | 20 Minn. 494 (1874)
Imagine you enter into a contract requiring you to perform a specific task. But each time you try to perform it, some external factor prevents you from succeeding. Does that external factor legally excuse you from your contractual obligation? The Minnesota Supreme Court addressed this issue in Stees versus Leonard.
Charles Leonard and his building partners entered into a contract with John and Washington Stees to construct a three-story building on the Steeses’s land. The contract included plans and specifications for the building. Leonard and his partners completed much of the work on the building before it imploded to the ground. Thereafter, Leonard and his partners began the construction process a second time, but the building again imploded after the third story was completed. The building kept collapsing because the soil was porous and was absorbing excessive amounts of water. At that point, Leonard informed the Steeses that he and his partners couldn’t construct the building according to the plans and specifications because the ground was incapable of holding the weight of a three-story building. Stees then sued Leonard and his partners for breach of contract. At the trial, Leonard tried to offer testimony that the Steeses had orally promised to drain the land so that the soil would support a three-story building. The trial court excluded that testimony under the parol-evidence rule, which generally prohibits proof of oral promises that aren’t contained in a written contract. The jury returned a verdict for the Steeses.
Leonard and his codefendants appealed to the Minnesota Supreme Court.
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