Butler v. Benefield
1979 Tex. App. LEXIS 4178, 589 S.W.2d 778 (1979)
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Rule of Law:
A property description in a real estate contract must furnish the means to identify the specific land with reasonable certainty. A description consisting of a street address, city, and state is not sufficient or insufficient as a matter of law; its validity under the Statute of Frauds depends on extrinsic evidence proving that the description points to a single, identifiable property.
Facts:
- On February 27, 1978, Frank Butler entered into a written contract to sell property described as “415 Holley, Sherman, Texas” to Ricky and Terri Benefield for $19,500.
- The Benefields paid Butler a $200 earnest money deposit as part of the agreement.
- On March 1, 1978, an agent for the Benefields contacted Butler to request possession of the property by March 10, a date earlier than stipulated in the contract.
- Butler considered the request for early possession to be a breach of the contract by the Benefields.
- In response, Butler returned the Benefields' earnest money and notified them that he would not proceed with the sale.
- After the Benefields filed a lawsuit, Butler discovered that he did not possess full title to the property, as his son owned a one-half undivided interest.
Procedural Posture:
- Ricky and Terri Benefield sued Frank Butler in a Texas trial court for breach of a real estate contract.
- Both parties filed motions for summary judgment.
- The trial court denied Butler's motion and granted a partial summary judgment for the Benefields on the issue of liability.
- A jury trial was held solely on the issues of damages and attorney’s fees, resulting in a verdict for the Benefields.
- The trial court entered a final judgment against Butler based on the summary judgment and jury verdict.
- Butler (appellant) appealed the judgment to the Texas Court of Civil Appeals, challenging the summary judgment on liability and the measure of damages.
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Issue:
Does a property description in a real estate contract that consists only of a street address, city, and state satisfy the Statute of Frauds as a matter of law?
Opinions:
Majority - Robertson, Justice
No, a property description consisting only of a street address does not satisfy the Statute of Frauds as a matter of law because its sufficiency is a question of fact that requires extrinsic evidence. The legal standard requires a description to identify the property with 'reasonable certainty.' While a street address can be sufficient if it points to a single, unambiguous property, it is legally insufficient if it is reasonably possible to locate more than one property fitting that description. The trial court erred by granting summary judgment because it cannot be determined from the contract alone whether '415 Holley, Sherman, Texas' is a sufficient description; the court must hear extrinsic evidence to resolve this factual issue. However, the court correctly found that the seller's willful breach entitled the buyers to benefit-of-the-bargain damages, measured by the difference between market value and contract price, irrespective of a later-discovered title defect that was not the reason for the breach.
Analysis:
This case clarifies the application of the Statute of Frauds to property descriptions in real estate contracts in Texas. It establishes that a street address is not presumptively valid or invalid; its legal sufficiency is a question of fact contingent on extrinsic evidence. This holding prevents summary judgment where the ambiguity of a description is a central issue, requiring factual development at trial. The decision also reinforces the principle that a seller's liability for a willful breach is based on their intent and reason at the time of breach, making a later-discovered inability to perform irrelevant to the measure of damages.
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