Part 3- Contracts, Chapter 16: Writing, Doc 6

Summary of Contract Cases and Issues Related to Statute of Frauds, Parol Evidence Rule, and Partial Performance 1. Case: Dyer and Walt Bennett Ford (Parol Evidence and Entire Agreement Clause)    Facts: Dyer purchased a car and claimed the salesperson told her sales tax was paid, but the written contract explicitly stated it was the entire agreement and no oral modifications would be recognized. Later, Dyer had to pay sales tax when licensing the car and sued for breach of contract. Issue: Whether Dyer can rely on the salesperson’s oral statements despite the entire agreement clause. Outcome: Given the parol evidence rule and entire agreement clause, the court likely ruled in favor of the dealership, preventing Dyer from using oral statements to alter the terms of the written agreement. 2. Case: Harrises v. Hallbergs (Oral Agreement Following Written Release)    Facts: After terminating a real estate purchase agreement and forfeiting their down payment, the Harrises claimed an oral agreement existed to refund the down payment if the property sold for more than $1.9 million. Issue: Enforceability of an alleged oral agreement post-written contract release. Outcome: Courts typically uphold the written release as the final agreement, particularly with independent legal representation and no written confirmation of the refund agreement. The Harrises would likely not succeed in enforcing the alleged oral agreement. 3. Case: Carrow v. Arnold and Mitchell (Misrepresentation Before Contract Execution)    Facts: Carrow sold his farm based on assurances from Arnold and Mitchell that he could continue farming the land. However, Arnold and Mitchell began development activities immediately after the sale. Issue: Whether Carrow can rescind the contract based on misrepresentation. Outcome: If Carrow can show that the assurances were material to his decision and constituted misrepresentation, he may succeed in his claim. However, the parol evidence rule may limit his ability to alter written contract terms unless he can prove fraud or misrepresentation. 4. Case: Chavez Family v. Bravo Estate and Cantu (Oral Contract and Partial Performance)  Facts: The Chavezes claimed an oral agreement to purchase a home, but after Bravo’s death, the new owner disputed the claim and treated their payments as rent.   Issue: Whether partial performance (payments and repairs) is sufficient to enforce an oral real estate contract under the statute of frauds. Outcome: If the court finds that the Chavezes’ actions constituted part performance (such as substantial improvements), they may enforce the oral contract. Otherwise, without written proof, the statute of frauds could bar their claim. 5. Case: Rosenfeld and Basquiat’s Crayon Contract (Sufficiency of Written Agreement under Statute of Frauds)    Facts: Rosenfeld claimed she purchased artwork from Basquiat, who wrote the terms in crayon on paper. The writing listed the paintings, the total price, a deposit, and both parties’ signatures. Issue: Whether the crayon document satisfies the statute of frauds. Outcome: Since the document includes the essential terms (items, price, signatures), it is likely sufficient under the statute of frauds, making it enforceable. 6. Case: Roose’s Divorce Fees and Burco’s Promise (Guaranty Agreement and Statute of Frauds)    Facts: Roose did not pay her legal fees. Her father, Burco, verbally promised to cover future expenses but later denied responsibility. Issue: Whether Burco’s oral commitment to pay his daughter’s legal fees is enforceable as a guaranty under the statute of frauds. Outcome: An oral guaranty typically requires a written agreement to be enforceable under the statute of frauds. Without written confirmation, Burco would likely not be held liable. Key Legal Concepts in These Cases:     Parol Evidence Rule: Courts enforce the terms of a written contract as the final agreement, barring oral modifications unless fraud or misrepresentation is proven. Statute of Frauds: Contracts involving real estate, goods over $500, or guaranties typically require written evidence to be enforceable. Entire Agreement Clauses: These clauses reinforce that no outside statements modify the written contract, protecting parties from claims based on prior or contemporaneous oral statements. Partial Performance Exception: Courts may enforce an oral contract when significant actions, like making improvements or partial payments, support the existence of an agreement, particularly in real estate cases. These cases highlight the importance of clear, written contracts, especially in highvalue transactions, and illustrate how statutes like the statute of frauds and parol evidence rule serve to prevent disputes over oral agreements.