Tertiary alkyl halides are too hindered for the SN2 reaction needed in Williamson synthesis. They prefer elimination, giving alkenes instead. So, we get a messy mixture, not our ether.
Actually, I saw something like this last week with our lab's old chloroform. My professor said it's like trying to push through a crowded market in Berhampur—too many methyl groups blocking the way. Bas, it made sense then.
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