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Keywords

contractbreach of contractplaintiffdefendantdamagesstatutecorporation

contractplaintiffdefendantstatute

Related Cases

Crabtree v. Elizabeth Arden Sales Corp., 105 N.Y.S.2d 40

Facts

Nate L. Crabtree was employed as a sales manager by Elizabeth Arden Sales Corporation under an oral contract that specified his salary and duration of employment. The contract stipulated a salary increase after the first year, but the defendant failed to pay the increased amount after October 22, 1948. Crabtree continued to work for the company until June 15, 1949, during which he complained about the unpaid increase but was told to be patient. After leaving the company, he sought other employment but was unsuccessful in finding a comparable position.

Under the contract established, plaintiff was to be paid at the rate of $20,000 a year for the first six months, $25,000 a year for the second six months, and $30,000 a year for the second year.

Issue

Did the defendant breach the employment contract by failing to pay the agreed salary increase, and was there sufficient written evidence to satisfy the Statute of Frauds?

Defendant contends that the contract may not be enforced because there was no memorandum signed by the defendant sufficient to satisfy the Statute of Frauds, and asserts in addition that the alleged contract is so indefinite that it is incapable of enforcement.

Rule

If there is a valid oral contract, the requirements of the Statute of Frauds are met provided there is a sufficient written memorandum containing the essential terms of the contract. The memorandum may be informal and consist of several writings.

If there is a valid oral contract the requirements of the Statute of Frauds are met provided there is a sufficient written memorandum containing the essential terms of the contract. The memorandum may be informal and need not be contained in a single instrument but may consist of several writings.

Analysis

The court determined that the written evidence, including a memorandum and payroll records, was sufficient to satisfy the Statute of Frauds. It found that the contract was not indefinite, as it clearly specified the rate of compensation and the duration of employment. The defendant's failure to pay the agreed salary constituted a breach of contract, and the court noted that the defendant did not provide evidence that Crabtree could have obtained similar employment.

The proof before me established that plaintiff and defendant made an oral contract whereby plaintiff was to serve as defendant's sales manager and that all of the essential terms thereof were acknowledged and evidenced in writing.

Conclusion

The court ruled in favor of Crabtree, awarding him damages totaling $14,041.61 for the unpaid salary and expenses.

Judgment is directed in favor of the plaintiff for $14,041.61.

Who won?

Plaintiff, Nate L. Crabtree, prevailed because the court found sufficient evidence of the contract and determined that the defendant breached it by failing to pay the agreed salary.

I accordingly hold that there was sufficient evidence to satisfy the Statute of Frauds and that this defense is without merit.

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