Angel v. Tauch (Opinion)
Annotate this Case
The Supreme Court held that no contract to settle a debt was formed in this case, that the implied-revocation doctrine is not constrained to real-property transactions, and that the settlement offer was impliedly revoked when the offeror assigned the underlying judgment.
At issue in this contract dispute was whether a purported offer to settle a debt for a reduced sum was accepted before it was revoked. The issue's resolution turned on the parameters of the doctrine of implied revocation adopted by the Supreme Court in Antwine v. Reed, 199 S.W.2d 482 (Tex. 1947). The trial court granted summary judgment against the offeree. The court of appeals reversed. The Supreme Court reversed, holding (1) the implied-revocation doctrine is not limited to offers involving the sale of land; and (2) the settlement offer in this case was impliedly revoked when the offeror assigned the underlying judgment to a third party for collection and the assignee gave the offeree a copy of the assignment agreement before the offeree accepted the settlement offer.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.