Lige Dickson Co. v. Union Oil Co.

96 Wash. 2d 291, 635 P.2d 103 (1981)



The court must hold that promissory estoppel cannot be used to overcome the statute of frauds in a case which involves the sale of goods. The Uniform Commercial Code was adopted to regulate commercial dealings. Uniformity among different jurisdictions in decisions concerning commerce was a major motivation behind development of the U.C.C. By so doing, it was hoped that this area of the law would become clearer and disputes would be more readily resolved. 


Plaintiff alleged that he had an oral contract to buy asphalt at a fixed price from defendant.  Plaintiff entered into contracts in reliance on the oral agreement.  Defendant then raised the asphalt prices, causing plaintiff financial losses. Plaintiff filed an action against the defendant. The trial court sustained general demurrers to the complaint and amended complaint and dismissed the action. It held that there was an oral contract between the parties but the statute of frauds, Wash. Rev. Code. § 62A-2-201, rendered the contact unenforceable. 


Can the doctrine of promissory estoppel be used to make an oral contract enforceable?




On appeal, the court addressed whether an oral promise within the statute of frauds could be enforceable on the basis of promissory estoppel. The court held that promissory estoppel could not be used to overcome the statute of frauds in the sale of goods.

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