911 N.W.2d 833
Minn.2018Background
- James Christie alleges an oral agreement with his parents that they would reconvey a 470-acre farm to him after they paid a mortgage (which he would pay off), and he did pay the mortgage; the parents (and their estates) later refused to reconvey.
- The written deed shows James conveyed the property to his parents; there is no written agreement to reconvey.
- First trial: district court granted JMOL for the Estates, concluding the statute of frauds barred enforcement; court of appeals reversed and remanded.
- Second trial: tried as a breach-of-contract claim seeking money damages only; the district court instructed the jury to apply the preponderance standard; the jury found an oral contract existed and awarded market-value damages.
- The Estates moved for judgment as a matter of law or a new trial, arguing the correct standard to prove an oral land-sale contract is clear and convincing evidence and that the verdict lacked support. The district court and court of appeals rejected the argument.
- The Minnesota Supreme Court granted review and reversed, holding the clear-and-convincing standard applies to proof of oral contracts for the sale of land regardless of whether damages or specific performance is sought, and remanded for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicable evidentiary standard to prove existence of an oral contract for sale of land | Christie: preponderance of the evidence suffices when only money damages are sought | Estates: clear and convincing evidence required for oral land-sale contracts regardless of remedy | Held: clear and convincing evidence is required regardless of whether plaintiff seeks damages or specific performance |
| Whether statute of frauds can be avoided by detrimental reliance (part performance) | Christie: detrimentally relied on the oral agreement (payments, reduced sale price) so statute of frauds should not bar enforcement | Estates: no clear and convincing proof of the alleged agreement, so part-performance exception does not apply | Held: Because jury was instructed under wrong standard, court remanded for retrial; part-performance analysis must be evaluated under clear-and-convincing proof at retrial |
| Whether jury instruction and standard used warranted a new trial | Christie: preponderance instruction was proper because remedy was damages | Estates: erroneous instruction was prejudicial and requires new trial | Held: Instruction was erroneous and prejudicial; new trial required |
| Sufficiency of evidence supporting jury verdict | Christie: evidence (payments, transaction circumstances) sufficed under preponderance standard | Estates: evidence insufficient absent clear and convincing proof | Held: Court did not decide sufficiency under clear-and-convincing standard; remanded for new trial to apply correct standard |
Key Cases Cited
- Ehmke v. Hill, 51 N.W.2d 811 (Minn. 1952) (clear and convincing evidence required to warrant specific performance of an oral contract to give real property by will)
- Anderson v. Anderson, 266 N.W. 841 (Minn. 1936) (parties conceded oral contract seeking specific performance must be proved by clear, positive, and convincing evidence)
- Kavanagh v. Golden Rule, 33 N.W.2d 697 (Minn. 1948) (oral modification of written contract requires clear and convincing evidence)
- Theisen's, Inc. v. Red Owl Stores, Inc., 243 N.W.2d 145 (Minn. 1976) (heightened standard where facts must be consistent, clear, and convincing)
- Clark v. Clark, 288 N.W.2d 1 (Minn. 1979) (specific performance of an oral contract to make a will requires clear, positive, and convincing evidence)