Nate L. Crabtree v. Elizabeth Arden Sales Corp. case brief summary
110 N.E.2d 551 (1953)
CASE SYNOPSIS:Defendant appealed a judgment from the Appellate Division of the New York Supreme Court that affirmed a judgment of the New York Supreme Court for New York County in favor of plaintiff in a breach of contract action related to an employment contract.
FACTS:
-The Plaintiff sought a three year contract for employment with the Defendant.
-The Plaintiff was leaving a secure job in order to to enter a new field and wanted the employment agreement to be for a definite term.
-Instead, the Defendant offered the Plaintiff a two year employment contract with an annual salary of $20,000 for the first six months, $25,000 for the following six months, and $30,000 for the second year.
-Plaintiff stated that the offer was “interesting.”
-Defendant had the offer written upon a telephone order.
-A few days later, the Plaintiff accepted the offer.
-Plaintiff began working and received the first increase in income after six months, however, the Plaintiff did not receive the subsequent increase.
-Defendant’s comptroller and general manager each had signed a payroll change card in the attempt to remedy the situation.
-However, this increase was not approved and the Plaintiff left his employment with the Defendant and brought this cause of action on theory of breach of contract.
HOLDING:: The court affirmed a judgment in favor of plaintiff in a breach of contract action related to an employment contract. The court held that an unsigned office memorandum, together with two signed payroll cards, were sufficient under the statute of frauds, N.Y. Pers. Prop. Law §31, to establish an employment contract with a tenure of two years.
ANALYSIS:
-All three documents referred on their face to the same transaction and the terms under which plaintiff would be employed by defendant, and contained all of the essential terms of the contract between the parties.
-In addition, parol evidence was admissible to prove the circumstances of the agreement and the relationship between the documents because it did not supply any of the terms of the contract.
-The court therefore held that the length of the contract could be established through reference to the unsigned office memorandum without violating the statute of frauds.
RULE:
To satisfy the statute of frauds, more than one document may be linked together either expressly or impliedly by the subject matter and the occasion.
OUTCOME: The court affirmed a judgment in favor of plaintiff in a breach of contract action related to an employment contract because reference to an unsigned office memorandum to establish the length of the employment agreement, in conjunction with other signed documentation, did not violate the statute of frauds.
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110 N.E.2d 551 (1953)
CASE SYNOPSIS:Defendant appealed a judgment from the Appellate Division of the New York Supreme Court that affirmed a judgment of the New York Supreme Court for New York County in favor of plaintiff in a breach of contract action related to an employment contract.
FACTS:
-The Plaintiff sought a three year contract for employment with the Defendant.
-The Plaintiff was leaving a secure job in order to to enter a new field and wanted the employment agreement to be for a definite term.
-Instead, the Defendant offered the Plaintiff a two year employment contract with an annual salary of $20,000 for the first six months, $25,000 for the following six months, and $30,000 for the second year.
-Plaintiff stated that the offer was “interesting.”
-Defendant had the offer written upon a telephone order.
-A few days later, the Plaintiff accepted the offer.
-Plaintiff began working and received the first increase in income after six months, however, the Plaintiff did not receive the subsequent increase.
-Defendant’s comptroller and general manager each had signed a payroll change card in the attempt to remedy the situation.
-However, this increase was not approved and the Plaintiff left his employment with the Defendant and brought this cause of action on theory of breach of contract.
HOLDING:: The court affirmed a judgment in favor of plaintiff in a breach of contract action related to an employment contract. The court held that an unsigned office memorandum, together with two signed payroll cards, were sufficient under the statute of frauds, N.Y. Pers. Prop. Law §31, to establish an employment contract with a tenure of two years.
ANALYSIS:
-All three documents referred on their face to the same transaction and the terms under which plaintiff would be employed by defendant, and contained all of the essential terms of the contract between the parties.
-In addition, parol evidence was admissible to prove the circumstances of the agreement and the relationship between the documents because it did not supply any of the terms of the contract.
-The court therefore held that the length of the contract could be established through reference to the unsigned office memorandum without violating the statute of frauds.
RULE:
To satisfy the statute of frauds, more than one document may be linked together either expressly or impliedly by the subject matter and the occasion.
OUTCOME: The court affirmed a judgment in favor of plaintiff in a breach of contract action related to an employment contract because reference to an unsigned office memorandum to establish the length of the employment agreement, in conjunction with other signed documentation, did not violate the statute of frauds.
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Interested in learning how to get the top grades in your law school classes? Want to learn how to study smarter than your competition? Interested in transferring to a high ranked school?
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