Legal Capacity to Sign Contracts . . . . Dizzy Dean

Legal capacity to sign a contract became an issue early in the career of Hall-of-Fame pitcher Dizzy Dean. After signing with the St. Louis Cardinals as a teenager, Dizzy was promoted to the parent club in 1932. Although he had not yet pitched a full season in the major leagues, Dean had already proclaimed himself as baseball's new "wonder boy." Befitting that view, he was unhappy with his salary. In Dizzy's mind, his contract was not valid. Dizzy informed Sam Breadon, the Cardinals' owner, that he wanted his unconditional release. To justify his demand, Dizzy invoked a fundamental principle of contract law. "I'm not yet 21," he announced, " and my father didn't sign this year's contract like he did the others. So it's no good and I'd like to be turned loose." Dizzy had correctly construed the law of contracts. At that time in Missouri, any person under 21 was a minor. In cases where minors do sign a contract, the courts generally will allow them to break it. Dean, however, had difficulty separating fact from fiction. He was correct in his understanding of contract law, but the facts were against him. The Cardinals' records showed Dean to be 22 years old. The team confronted him. "Yah," he said, coming clean, "I'm 22 all right. I musta been thinkin" of my brother Paul's birthday. He'll be 22 one of these days. Or is it 20? Or 19? I reckon I'll have to ask him." Dean would have had an even more difficult case under the law today. Like most states, Missouri now allows anyone 18 years or older to enter into contracts.