Crabtree v. Elizabeth Arden Sales Corp - 105 N.Y.S.2d 40 (Sup. Ct. 1951)

Rule:

If there is a valid oral contract the requirements of the Statute of Frauds are met provided there is a sufficient written memorandum containing the essential terms of the contract. The memorandum may be informal and need not be contained in a single instrument but may consist of several writings. All that is required is that there be sufficient written evidence of the contract between the parties.

Facts:

Plaintiff employee and the defendant employer entered into an oral agreement for the employee to serve as the employer's sales manager. Through a written memorandum, telegrams between the parties, and payroll records the agreement was established. The employer failed to pay the increased rate of salary to the employee as established in the previous writings. The employee filed an action for breach of contract. The employer contended that the contract could not be enforced because there was no memorandum signed by the employer sufficient to satisfy the Statute of Frauds.

Issue:

Did the writings between the plaintiff and the defendant satisfy the Statute of Frauds, thereby warranting judgment in favor of the plaintiff employee? 

Answer:

Yes.

Conclusion:

The court disagreed with the defendant employer, and stated that the writings between the parties satisfied the Statute of Frauds. Further, the court stated that the contract was not indefinite because the writing specified the rate of compensation, as well as the duration of two years. The court determined that the damages were the difference of salary from the contract compared with what the employee was paid prior to the time he left his job with the employer. The court further held that the employer was not entitled to a reduction of damages because it offered no proof that the employee could have obtained a similar position had he acted with reasonable diligence.