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Crabtree v. Elizabeth Arden Sales Corp

Citation. 22 Ill.305 N.Y. 48, 110 N.E.2d 551 (1953)
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Brief Fact Summary.

Plaintiff Crabtree alleges that Defendant Elizabeth Arden Sales Corp. breached a two year employment contract.

Synopsis of Rule of Law.

More than one document may be linked together either expressly or impliedly by the subject matter and occasion to supply a memo to satisfy the statute of frauds.


Plaintiff sought a three year employment contract with Defendant. Plaintiff was leaving a secure job to enter a new field and wanted the agreement to be for a definite term. Defendant instead offered Plaintiff a two year employment contract with an annual salary of $20,000 for the first six months, $25,000 for the next six months, and $30,000 for the second year. Plaintiff called the offer “interesting.” Defendant had the offer written down on a telephone order.
A few days later, Plaintiff accepted the offer. Plaintiff began working and received the first increase in income after six months, but did not receive the subsequent increase. Defendant’s comptroller and general manager each signed a payroll change card to attempt to remedy the situation. However, the increase was not approved and Plaintiff left his employment with Defendant and brought this cause of action for breach of contract.


Was the lower court justified in finding that the contract satisfied the statute of frauds?


Yes. The lower court was justified in finding that the contract satisfied the statute of frauds
Because the contract cannot be performed in under a year, it falls under the statute of frauds. If a contract falls under the statute of frauds it must have a sufficient memo that is signed with the intent to authenticate the terms and evidences the terms of the contract. The memo does not have to be one document. It may be multiple documents if they are linked together expressly or internally by evidence of subject matter and occasion.
The Court finds in this case that the memo written on the telephone order, the payroll change form initialed by Defendant’s general manager, and the paper signed by Defendant’s comptroller all refer to the same transaction on their face. The Court holds that the lower court was justified in finding that the three documents comprised a sufficient memo.


In the present case, the trial court was justified in finding a sufficient memo to satisfy the statute of frauds by linking the three documents together.

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