Wednesday, December 18, 2013

Shaughnessy v. Eidsmo case brief

Shaughnessy v. Eidsmo case brief summary
23 N.W.2d 362 (1946)


CASE SYNOPSIS
Defendant seller sought review of an order from the District Court for Hennepin County (Minnesota), which entered a judgment for plaintiff buyers in a suit seeking the specific performance of an alleged contract for the sale of real estate. The seller's motion for a new trial was denied.

CASE FACTS
The buyers claimed that the seller failed to execute a contract of deed after the buyers exercised their option under an oral lease agreement to purchase the property at the expiration of the lease. The buyers filed a suit for the specific performance of the sales contract, and the trial court entered a judgment for them and denied the seller a new trial.

DISCUSSION

  • On appeal, the court held that the evidence supported the trial court's findings. 
  • The court further held that the option contract was not an interest in land and was not within Minn. Stat. § 513.04 (1941), the statute of frauds. 
  • The court also held that although the parties' oral lease was within the statute, its had been fully performed when the buyers exercised their purchase option. 
  • The court then held that the oral sales contract was taken out of the statute because the trier of fact properly found that the buyers' continued possession of the premises with the seller's consent, along with their payments towards the purchase price, constituted part performance of the contract. 
  • Finally, the court held that the buyers did not have to prove irreparable injury in order to take the oral sales contract out of the statute.

CONCLUSION
The court affirmed the judgment for the buyers and the denial of the seller's motion for a new trial.


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