McIntosh v. Murphy

469 P.2d 177 (1970)

Quick Summary

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Dick McIntosh (plaintiff) sued George Murphy and Murphy Motors, Ltd. (defendants) for breach of an alleged oral employment contract. The trial court ruled that the contract did not violate the Statute of Frauds, and a jury awarded damages to the plaintiff.

The Supreme Court affirmed the judgment based on equitable estoppel, allowing the plaintiff to recover damages.

Facts of the Case

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In March 1964, while George Murphy and Murphy Motors, Ltd. (defendants) were in southern California conducting interviews for their car dealerships in Hawaii, George Murphy interviewed Dick McIntosh (plaintiff) twice for the position of sales manager. Although no contract was entered into then, the plaintiff received a call in April informing him of possible employment within thirty days if he was still available.

The plaintiff confirmed his interest and informed the manager he would be available. The plaintiff then sent a telegram stating that he would arrive in Honolulu on April 26, 1964.

On April 25, 1964, Murphy called the plaintiff to notify him that the job title had changed to assistant sales manager and work would begin on April 27, 1964. The plaintiff arrived in Honolulu on April 26 and started working the next day.

However, he was terminated on July 16, 1964, after being unable to close deals and train salesmen.

Procedural Posture and History

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  1. The trial court ruled that the alleged employment contract was not within the Statute of Fraud.
  2. The case went to trial, and the jury awarded the plaintiff $12,103.40 in damages.
  3. The defendants appealed to the Supreme Court.

I.R.A.C. Format

Issue

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Whether an oral employment contract that allegedly violates the Statute of Frauds can be enforced based on the plaintiff’s reliance on the contract.

Rule of Law

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In cases where an oral contract violates the Statute of Frauds and reliance on the contract results in injustice, the court may apply equitable estoppel to enforce the contract.

Reasoning and Analysis

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The court determined that although the alleged employment contract came within the Statute of Frauds, the plaintiff’s reliance on the contract created a situation where injustice could only be avoided by enforcing the contract.

The court applied Section 217A of the Restatement (Second) of Contracts, which allows for the enforcement of promises if their performance was reasonably expected to induce action or forbearance on the part of the promisee and injustice can only be avoided by enforcement of the promise.

In this case, the plaintiff had moved from Los Angeles to Honolulu, sold possessions, and leased an apartment, all in reliance on the alleged employment contract. Enforcing the contract was the only way to prevent him from suffering a significant loss.

Conclusion

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The court affirmed the trial court’s judgment, allowing the plaintiff to recover damages based on his reliance on the alleged oral employment contract.

Dissenting Opinions

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Justice Abe dissented, arguing that the trial court erred in ruling that the alleged employment contract did not violate the Statute of Frauds. He also disagreed with using equitable estoppel to enforce a contract that falls within the Statute.

Key Takeaways

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  1. Reliance on an oral contract that violates the Statute of Frauds may result in equitable estoppel being applied to enforce the contract.
  2. Section 217A of the Restatement (Second) of Contracts guides when injustice can only be avoided by enforcing an oral promise.
  3. Courts have discretion in determining whether to enforce contracts that violate the Statute of Frauds based on equitable principles.

Relevant FAQs of this case

How does the court handle oral contracts violating the Statute of Frauds?

Oral contracts violating the Statute of Frauds are often unenforceable in court, unless an exception, like performance or partial performance, applies. The statute aims to prevent fraudulent claims stemming from unreliable oral agreements.

What factors does the court consider in determining if reliance on an oral contract is reasonable?

Courts consider various factors to determine the reasonableness of reliance on an oral contract. Key factors include the complexity of the agreement, the parties’ experience, any actions taken based on the oral agreement, and whether there’s a history of dealings between the parties. In short, the court evaluates the overall circumstances to decide if relying on the oral contract was reasonable.

Can equitable estoppel apply even if the oral contract is subject to the Statute of Fraud?

Equitable estoppel can be applied to enforce an oral contract, even if it falls under the Statute of Frauds. If one party reasonably relies on the agreement and faces harm, the court may prevent the other party from using the Statute of Frauds as a defense.

  • For example: If a person quits a job and relocates for a promised position, the court might enforce the oral agreement if the Statute of Frauds applies, preventing unfair consequences.

References

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