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Kolkman v. Roth - 656 N.W.2d 148 (Iowa 2003)

Rule:

The doctrine of promissory estoppel does not eviscerate the statute of frauds, Iowa Code § 622.32 (1999), but only applies to circumvent the statute when necessary to prevent an injustice. It requires the party asserting it as a means to avoid the statute of frauds to prove: (1) a clear and definite promise; (2) the promise is made with the promissor's clear understanding that the promisee is seeking assurance upon which the promisee can rely and without which he will not act; (3) the promisee acts to his or her substantial detriment in reasonable reliance on the promise; and (4) injustice can be avoided only by enforcement of the promise.

Facts:

The landowner inherited the land. The tenant asserted that, pursuant to his oral agreement with the landowner,  the tenant could continue farming the land until he retired. Consequently, the tenant continued to improve the farm by performing work not typically done by a tenant farmer. However, after three years, the landowner sought to terminate the lease. The Iowa District Court found that the tenant established the elements of promissory estoppel and determined that the statute of frauds did not bar oral evidence of the farm lease. A jury then found the tenant and landowner had entered into a contract, supported by consideration, and that the landowner breached the contract. On appeal, the Iowa Court of Appeals affirmed the lower court decisions. The landowner sought further review from the Supreme Court of Iowa.

Issue:

Is promissory estoppel doctrine available as an exception to the statute of frauds for leases claimed to be in excess of one year?

Answer:

Yes

Conclusion:

The Iowa Supreme Court concluded the promissory estoppel doctrine was available as an exception to the statute of frauds for leases claimed to be in excess of one year. Thus, the court affirmed the decision of the court of appeals and the judgment of the district court.

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