What is Mailbox Rule?
The Mailbox Rule governs when an offer is accepted, therefore forming the contract. The rule states that the offer is accepted as soon as the offeree places their acceptance in the mailbox, so long as it is addressed properly and has sufficient postage. In the modern era, courts have applied the mailbox rule to emails, stating that an offer is accepted once the offeree accepts via email to the correct email address. The mailbox rule is also sometimes referred to as the posting rule.
Case Examples
- Appeals: In Anania v. McDonough, 1 F.4th 1019, 1022 (Fed. Cir. 2021), a veteran appealed his denial of disability benefits. The agency claimed that his appeal was not timely, and the veteran submitted a self-serving affidavit stating the date that he mailed the appeal. Id. The Court noted that “if a letter properly directed is proved to have been either put into the post office or delivered to the postman, it is presumed, from the known course of business in the post office department, that it reached its destination at the regular time, and was received by the person to whom it was addressed” Id. The Court also noted that “self-serving affidavits are not per se insufficient to establish presumption of receipt under mailbox rule.” Id.
- Employment: In Baghdasarian v. Macy's, Inc., No. CV2104153ABMAAX, 2021 WL 12251599, at *4 (C.D. Cal. Oct. 28, 2021), an employee claimed her employer never made her aware of the arbitration clause in her contract and did not send her the required paperwork. The Court found that a specific factual denial of receipt of notice rebuts the presumption of receipt, which is to be given no further weight.” Id.
- The Mailbox Rule in Prison: Due to prisoners’ limited access to mail and the fact that many prisoners are going through the court system pro se, there is a special version of the mailbox rule for prisoners, known as the prison mailbox rule. In Huskey v. Fisher, 601 F. Supp. 3d 66, 75 (N.D. Miss. 2022), “a pro se prisoner's court document is deemed to have been filed on the date that the prisoner delivers it to prison authorities for mailing to the district court, rather than the date it is received by the court clerk.” The court explained that “[a] pro se prisoner is unskilled in law, unaided by counsel, and unable to leave the prison. His control over the processing of his motion ends as soon as he hands it over to the prison authorities, and the only information he will likely have is the date he delivered the motion to those authorities and the date ultimately stamped upon it.” Id.
Further Reading
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