Crabtree v. Elizabeth Arden Sales Corp.
305 N.Y. 48 · New York Court of Appeals · 1953
Facts
Nate Crabtree negotiated a two-year employment contract with Elizabeth Arden Sales Corp. for a sales manager position with escalating salary. An unsigned office memorandum and two signed payroll change cards documented the terms. After receiving the first salary increase, Crabtree was denied the second, leading to his termination and a breach of contract suit, which the defendant argued was barred by the Statute of Frauds.
Issue
Can multiple documents, some signed and some unsigned, be pieced together with the aid of parol evidence to satisfy the Statute of Frauds for an employment contract not performable within one year, and can parol evidence explain ambiguous terms?
Holding
Yes, the court affirmed the lower court's judgment for the plaintiff, holding that the multiple documents, when read together and connected by parol evidence, satisfied the Statute of Frauds and established a two-year contract.
Rule
A memorandum satisfying the Statute of Frauds may be pieced together from separate signed and unsigned writings if they clearly refer to the same subject matter or transaction. Parol evidence is admissible to connect the documents, show assent to the unsigned writing, and explain ambiguous terms, provided all essential terms are in the writings and at least one writing is signed by the party to be charged.
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