Facts: Sun Valley owned over one acre of a lot that was undeveloped. Hoffman took Sun Valley to district court based off of things in the agreement. The judged ruled that there was an oral understanding of the sale but they didn’t comply with statue of frauds and because of this the agreement was unenforceable.
Issue: Is there an enforceable contract to sell the property of Sun Valley? Are the two documents, the letter and check, sufficient to satisfy the statutory requirements?
1) Was there an oral agreement and is there sufficient memorandum signed by the parties that evidences the agreement so that the statute of frauds is satisfied?
Holding: Yes and No. Yes, they did come to a mutual agreement however, the agreement did not comply with the statute of frauds and the agreement is not enforceable.
Majority Opinion Reasoning: Justice Shepard
1) A contract require that the parties have a specific understanding
2) Idaho requires that both parties sign the documents while the rest of other jurisdictions require only one party to sign the documents
1) The parties had negotiated the purchase price which was then approved by the executive committee. The agreed upon price was $90,000 which could be paid in cash or they could do a 30% down payment on the land. Hoffman sent Sun Valley a check and an email which listed additional terms.
2) The sale agreement was never signed by Sun Valley.
3) Hoffman says he exercised buyer rights because they had someone come survey the land.
Concurring Opinion(s) Reasoning: Bakes, C.J., McFadden and Donaldson, JJ, concur
Dissenting Opinion(s) Reasoning: Bistline
Bistline stated that Idaho’s law may be outdated and possibly need to be changed. When parties have as much documentation as these two parties did and it still doesn’t meet the requirements OF Statute of Frauds, then the laws can’t accommodate to the business transactions in the world today. While the majority of other jurisdictions only require one signature on documents, Idaho requires both parties to sign the documentation. Bistline thinks that Idaho needs to follow in the footsteps of others in a more updated and modern law. The court needs to consider the possibility of this law being outdated.