Laidlaw v. Organ

178 (1817), is a case decided by the Supreme Court of the United States that established the rule that buyers need not disclose advantageous information to sellers.

In consequence of the blockade, tobacco crops coming down the Mississippi River intended for export amassed in New Orleans, thereby depressing their price by 23 to 33 percent.

Within the hour after publication of the handbill on February 19, Organ finalized a contract with Girault to purchase 111 hogsheads of tobacco (120,000 pounds).

Writing for a unanimous court, Chief Justice Marshall held in a short opinion of 120 words that Organ had no duty to disclose information known exclusively to him about circumstances affecting the price of the commodity he was purchasing.

The Court viewed a rule requiring purchasers to disclose such information when it was readily discoverable to the seller as judicially unmanageable.

Laidlaw has been cited by 110 different cases and maintains great importance in U.S. legal scholarship and education (including law school contracts courses).

[2][3] Laidlaw has also faced criticism from an economic perspective on the idea that nondisclosure of information that will shortly become public does not encourage overall efficiency because it merely affects distribution.