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Connecticut Supreme Court - 220 Conn. 569
Tags: Contracts, Statute of frauds, One-year rule
tl;dr:
A company and a man they wanted to hire publicized their agreement to work together and shook on it, but they never entered into a written agreement for most of the job to be done. The company became unhappy with the man's work and hired someone else.Video Summary
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The case involves a dispute between C.R. Klewin, Inc. and Flagship Properties and DKM Properties, who do business together as Conn-Tech, regarding a construction project in Mansfield, Connecticut. Klewin claimed breach of an oral contract, quantum meruit recovery, and detrimental reliance after Flagship contracted with another contractor for the next phase of the project. The district court granted summary judgment, stating that the alleged oral contract was barred by the statute of frauds. The Connecticut Supreme Court answered that an oral contract without a specified time for performance is enforceable, but an oral contract requiring more than one year for performance must explicitly state that performance cannot be completed within one year to be enforceable. The Connecticut statute of frauds was created to prevent perjury and subornation of perjury in the King's courts by requiring a written memorandum or note, signed by the party to be charged, for specified transactions. Despite being repealed by the British Parliament in 1954, it is still in effect in most of the United States. The one-year provision, which measures the time from the making of the contract to the completion of performance, is flawed because it can apply to an oral contract for one day of work, 13 months in the future, but not to an oral contract for a year of work starting today.
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