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Maine Supreme Judicial Court - 861 A.2d 625, 861 A.2d 625,2004 ME 134
tl;dr:
Partial performance of an oral agreement to buy land, induced by seller's misrepresentations, overcomes the statute of frauds' writing requirement.Video Summary
Case Summary
In the 2004 case Sullivan v. Porter, Joan Sullivan and David Andrews sued a farmer, Merval Porter Jr. and his wife Susan for not honoring an oral agreement to sell their land. The couple had agreed to buy the farm for $350,000, given a $3,000 down payment, and started a business on the property. Despite promising to provide the necessary written contract, Porter never did, and later raised the price to $450,000.
Sullivan sued for specific performance, arguing that the Porters couldn't back out of the agreement. The Porters claimed the contract needed to be in writing according to the statute of frauds. Ultimately, the court sided with Sullivan, finding the oral contract valid and ordering the Porters to complete the sale. The exception to the statute of frauds came from the part performance doctrine, as Sullivan had partially performed the agreement and the Porters misled them.
This case demonstrates the statute of frauds, a legal principle requiring certain contracts, like land sales, to be in writing to prevent fraud and promote certainty. However, exceptions like part performance exist, allowing oral contracts to be valid if the actions of the parties sufficiently support them. This balances the need for formal contracts with the pursuit of fairness and justice.
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The Porters are appealing the judgment in favor of Sullivan and Andrews, claiming that there was not enough evidence to support the jury's finding of an oral contract for the sale of their farm. The higher court has upheld the judgment, stating that there was indeed an oral contract and that the essential material terms of the contract were sufficiently clear, even if certain details were expressed within a range. The court found that there was a meeting of the minds.
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