Wednesday, December 18, 2013

Potter v. Hatter Farms, Inc. case brief

Potter v. Hatter Farms, Inc. case brief summary
641 P.2d 628 (1982)

Defendant company appealed an order from the Circuit Court, Marion County (Oregon) which entered a jury verdict in favor of plaintiff companies.

Plaintiff companies and defendant company entered into an oral contract for the purchase of poults, but the exact means for transporting the poults was left out of the contract. In June, plaintiffs turned down an offer from another company to purchase poults because plaintiffs thought defendant still intended to buy the poults. In August, defendant notified plaintiff that it would be unable to use the poults.

The court held that there was sufficient evidence to support a finding that the parties had entered into an oral contract.


  • The court found that even though the transportation term was left open, it was not fatal to the agreement because plaintiffs testified that the agreement was not conditioned upon finding ideal transportation. 
  • Defendant's statute of frauds defense was not applicable because plaintiff satisfied the actual reliance and substantial change of position requirements under promissory estoppel when it relied on defendant's promise in June.

The court affirmed because there was substantial evidence of the existence of an oral contract between plaintiffs and defendant and because defendant's assertion of the defense of the statute of frauds was barred by promissory estoppel.

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