Radke v. Brenon
134 N.W.2d 887 (1965)
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Rule of Law:
A written memorandum for the sale of land can satisfy the Statute of Frauds, even with minor technical imperfections, if it contains the essential terms of the agreement and the surrounding evidence, including the seller's in-court admission, clearly proves the existence of an oral contract.
Facts:
- Plaintiff and Defendants (Brenons) were neighbors whose residential lots were separated from a nearby lake by a strip of land.
- Preston Brenon purchased the entire strip of land on December 1, 1959.
- On June 28, 1960, Brenon sent a letter with his typewritten name to Plaintiff and other neighbors, offering to sell each of them the parcel adjoining their property for an equal share of his total cost, initially calculated at $212.
- Plaintiff orally accepted the offer approximately two weeks after receiving the letter.
- After two other neighbors declined to purchase their parcels, the price for Plaintiff's parcel was recalculated to $262 according to the cost-sharing formula in the letter, and Plaintiff agreed to pay this increased amount.
- Plaintiff's attorney notified Brenon on August 16 that he held a check for $262 and was ready to complete the purchase upon receipt of a deed.
- After this notification, Brenon sent a letter also dated August 16, informing the Plaintiff that the offer to sell was revoked.
Procedural Posture:
- Plaintiff sued Defendants in district court (trial court) seeking specific performance of the contract for the sale of real estate.
- The trial court found for the Plaintiff, concluding a valid contract existed and that Defendants had wrongfully refused to complete the sale.
- The trial court entered a judgment ordering specific performance.
- Defendants (Appellants) appealed the judgment to the Minnesota Supreme Court.
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Issue:
Does a letter with a typewritten name, which outlines the essential terms of a land sale including a formula for the price, constitute a sufficient written memorandum to satisfy the Statute of Frauds, even if the final price varies from the initial figure in the letter?
Opinions:
Majority - Rogosheske, Justice.
Yes. The letter constitutes a sufficient written memorandum to satisfy the Statute of Frauds. The court's role is to uphold the policy of the Statute of Frauds, which is to prevent fraud, not to allow its technicalities to be used to repudiate a contract that was actually made. The letter contained the essential terms: the parties, the land (identified by an accompanying survey), and the general conditions of the sale. The discrepancy in price was not fatal because the letter provided the clear formula for calculating the price, and the final amount was merely a mathematical computation based on that formula. Furthermore, Brenon's typewritten name was a sufficient 'subscription' because he testified that he intended it to be his signature. Most persuasively, Brenon admitted in court that an oral contract had been made, which strongly supports the conclusion that enforcing the contract prevents the statute from being used as an instrument of fraud.
Analysis:
This decision represents a flexible, policy-driven application of the Statute of Frauds, prioritizing its purpose of preventing fraud over rigid adherence to its technical requirements. By considering the seller's in-court admission of a contract as a key factor, the court signals that it will not permit the statute to be used as a shield to escape a validly, if imperfectly documented, agreement. This approach empowers courts to look beyond the four corners of a memorandum to surrounding circumstances to prevent an unjust result, thereby potentially lowering the bar for what constitutes a sufficient writing in cases with strong extrinsic evidence of a contract.
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