Contracts II, Pages 679–685

Crabtree v. Elizabeth Arden Sales Corp.

Court of Appeals of New York, 1953

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Facts:

Plaintiff was in preliminary negotiations with defendant towards being employed as a sales manager. In a meeting with defendant's general manager, Johns, plaintiff requested a three-year contract at $25,000 per year. He then repeated this desire to defendant's president, Arden. Arden offered a two-year contract with $20,000 for the first six months, $25,000 for the second six, and $30,000 for the second year. Plaintiff said that this offer was "interesting." Arden gave plaintiff a memo of the offer though.

A few days later, plaintiff called Johns and telegraphed Arden that he accepted the "invitation to join the Arden organization." Arden replied, "welcome". A payroll card was made by Johns and sent to the payroll department with the offered pay rates. After six months, plaintiff received the pay increase to $25,000, but at the end of the year, he did not receive his increase to $30,000. The comptroller and Arden told plaintiff that they would attempt to straighten out the pay, and the comptroller prepared another payroll card to increase the pay to $30,000, but Arden refused to approve this. Defendant then left the company and sued for breach of contract.

Procedural History:

Trial court found against defendant and awarded plaintiff $14,000. The Appellate Division affirmed.

Issue:

Can the documents be combined to satisfy the statute of frauds collectively even though the documents do not refer to each other?

Defendant's Argument:

The contract was for more than one year, and thus required a writing under the statute of frauds. The memorandum has plaintiff's agreement and pay, but no signature. The employment cards have signatures, but do not refer to the two years of employment and do not refer to each other.

Reasoning:

The documents are consistent. They refer to the same price, person, job, and pay structure. Evidence shows that these refer to the same contract then, and both should be admitted.

Rule/Holding:

Yes, documents can be combined to satisfy the statute of frauds without referring to each other when there is no double in the matter.

Judgment:

Affirmed with costs.

Note:

Based on the Corbin approach, like the Restatement. Under the Williston approach, the court would not have admitted other evidence and required the documents to directly refer to each other.