Facts:Sun Valley owned a little over 1.
5 acres of anundeveloped lot. Hoffman took him to court to constrain certain performancesthat were in the agreement. While this was in district court, the judge decided”while an oral understanding for the sale of the property existed, there wasnevertheless failure to adequately comply with the statue of frauds and thusthe agreement was unenforceable.” The district court determined that the oralagreement for the sale of the property existed but it didn’t comply with thestatute of frauds making the agreement unenforceable. The district court alsodetermined that the equitable doctrines of part performance and estoppel didnot apply. Hoffman/Frey appealed to the SC and Sun Valley argued that theparties never reached a mutual agreement on the terms of the transaction (nocontract existed) Issue:Is there an enforceable contract to sell theproperty of Sun Valley?Are the two documents, the letter and check, sufficientto satisfy the statutory requirements?1) Was there an oral agreement and isthere sufficient memorandum signed by the parties that evidences the agreementso that the SoF is satisfied? Holding:Yes and No. Yes, the parties did come to an oralmutual agreement on the sale of the parties, however, the agreement did notcomply with the statute of frauds and the agreement is not enforceable. (1) The parties did have a mutualagreement regarding the terms of the transaction (sale of land)(2) Check issued by purchaser and letter written bypurchaser was insufficient as memorandum to take verbal agreement out ofstatute of frauds(3) Actions taken by purchasers were insufficient toestablish part performance to take contract out of statute of frauds(4) Principle of equitable estoppel is notapplicable to enforce oral contract MajorityOpinion Reasoning: Justice Shepard a) Rule:1) A contract requires that the partieshave a distinct understanding of what is agreed upon.
2) An agreement for the sale of realproperty is invalid unless the agreement or some note or memorandum thereof bein writing and subscribed by the party charged or his agent. Failure to complywith the statute of frauds renders an oral agreement unenforceable both in anaction at law for damages and in a suit in equity for specific performance. i. Idaho requires that both parties toa bilateral contract sign the memorandum even though the majority of otherjurisdictions require that only the party against whom the enforcement issought is required to sign. 3) Sufficient part performance by apurchaser of real property removes the contract from the operation of thestatute of frauds – i.
The most important acts whichconstitute sufficient part performance are actual possession, permanent andvaluable improvements and these two combined. 4) Equitable estoppel requirements arenot met. b) Application: 1) The parties negotiated for thepurchase price of the property and the price was approved by the executivecommittee.
They agreed on a price of$90,000 for the property and it could be paid in cash or with 30% down, withthe remainder to be paid over five years with a 9 ¾% interest rate. The buyersent Sun Valley (seller) an email and check confirming these details but italso contained additional terms. Sun Valley later deposited the check in it’strust account. Sun Valley prepared documents for the sale and loan and gavethem to Huffman/Frey but Sun Valley never executed them. These facts supportthat the parties reached a mutual agreement on the sale of the property.
2) The lot sale agreement was neversigned by Sun Valley. For the oral agreement to be enforceable, there mustexist a sufficient memorandum signed by the parties evidencing that agreement. 3) The lot sale agreement was neversigned by Sun Valley. The only document signed by both parties is the $5,000deposit check and it doesn’t reference Hoffman’s email/letter or the lot saleagreement.
4) Hoffman says they exercisedpossessory right by having the land surveyed and by submitting a subdivisionplan to the City of SV- cost of securing subdivision approval is notsubstantial enough ConcurringOpinion(s) Reasoning: Bakes, C.J., McFadden and Donaldson,JJ, concur DissentingOpinion(s) Reasoning: BistlineBistline says Idaho law is outdated and it needs to bechanged. If parties have as much or equal documentation like these parties andit doesn’t meet the requirements for SoF then Idaho’s case law is inadequate toaccommodate business transactions in today’s world.
Idaho law is not in linewith the majority of jurisdication and should follow others toward a moreupdated and modern law. Idaho should use a 70-year old decision to determine ifa enforceable agreement was made in today’s world. Court should considerwhether this law and its application is outdated and in need of change.