Courts: Emails Are Binding Contracts

Published May 31, 2016

Two recent court decisions in, respectively, Tennessee and Pennsylvania, have determined email exchanges can create legally binding contracts. In the former, emails were found to legitimize a real estate deal. In the latter, email was found to create a legally enforceable agreement to sell medical equipment.

The Tennessee case, Waddle v Elrod, was decided April 24. It involved a dispute between two family members over a parcel of land. A proposed settlement was emailed between the attorneys for both parties. A trial court concluded the phrase “that is the agreement” and signature line at the bottom of the email constituted a binding agreement, and the Tennessee Supreme Court concurred.

In Republic Bank Inc. v West Penn Allegheny Health System Inc., the U.S. Court of Appeals Tenth Circuit ruled a series of email messages between bank representatives and the hospital constituted an agreement to sell medical equipment. After the hospital backed out of the deal, the bank filed a breach of contract action against the hospital.

Internet Info

Waddle v. Elrod, Chief Justice Cornelia A. Clark, Tennessee Supreme Court Decision, April 24, 2012:

Republic Bank Inc. v. West Penn Allegheny Health Systems Inc., United States Court of Appeals Tenth Circuit Court, April 12, 2012: