Alaska Statutes
Alaska Stat. § 09.25.020 (2026)
Exceptions to statute of frauds
✓ current as of July 2026
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Sec. 09.25.020. Exceptions to statute of frauds.
A contract, promise, or agreement that is subject to AS 09.25.010, that does not satisfy the requirements of that section, but that is otherwise valid is enforceable if
(1) there has been full performance on one side accepted by the other in accordance with the contract;
(2) there is a memorandum that would satisfy the requirements of AS 09.25.010 except for error or omission in the recital of past events;
(3) there is a memorandum that would satisfy the requirements of AS 09.25.010 except for error or omission that could be corrected by reformation if it occurred in a formal contract;
(4) the party against whom enforcement is sought admits, voluntarily or involuntarily, in pleadings or at any other stage of this or any other action or proceeding the making of an agreement; or
(5) it is a contract of employment for a period not exceeding one year from the commencement of work under its terms.
A contract, promise, or agreement that is subject to AS 09.25.010, that does not satisfy the requirements of that section, but that is otherwise valid is enforceable if
(1) there has been full performance on one side accepted by the other in accordance with the contract;
(2) there is a memorandum that would satisfy the requirements of AS 09.25.010 except for error or omission in the recital of past events;
(3) there is a memorandum that would satisfy the requirements of AS 09.25.010 except for error or omission that could be corrected by reformation if it occurred in a formal contract;
(4) the party against whom enforcement is sought admits, voluntarily or involuntarily, in pleadings or at any other stage of this or any other action or proceeding the making of an agreement; or
(5) it is a contract of employment for a period not exceeding one year from the commencement of work under its terms.
Notes of Decisions
Cited in 1
case, 2015–2015 · leading case: Mun Seifert v. Eskimos, Inc., 617 F. App'x 771 (9th Cir. 2015).
Mun Seifert v. Eskimos, Inc., 617 F. App'x 771 (9th Cir. 2015). “Alaska Stat. § 09.25.020 (providing that full performance by one party accepted by the other according to the terms of the contract is a statutory exception to the Statute of Frauds); Mitchell v.”
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