performance doctrine (Missouri) · Go Syfert
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performance doctrine in Missouri

14 Missouri opinions name it 1 courts 1975–2025 1 in the last five years

The cases below were cited by Missouri courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (10)

CaseFollowedCited
Fire Sprinklers, Inc. v. Icon Contracting, Inc.green
moctapp · 2009 · cited in 2 Missouri opinions naming this issue, 2019–2019
2 sentences

2019Substantial performance is performance without a material breach, and a material breach results in performance that is not substantial.” Fire Sprinklers, Inc. v. Icon Contracting, Inc., 279 S.W.3d 230, 233 (Mo. App. E.D. 2009) (internal citation omitted).

2019Substantial performance is performance without a material breach, and a material breach results in performance that is not substantial.” Fire Sprinklers, Inc. v. Icon Contracting, Inc., 279 S.W.3d 230, 233 (Mo.App.

22
Johnson v. Cookgreen
moctapp · 2005 · cited in 2 Missouri opinions naming this issue, 2018–2025
2 sentences

2025See Johnson, 167 S.W.3d at 263-64 (holding the partial performance exception did not apply where no definite date for performance was established with clear, cogent, unequivocal, and convincing testimony).

2025Johnson, 167 S.W.3d at 263 (citing Lederle v. Lederle, 916 S.W.2d 423, 428 (Mo. App. E.D. 1996)) (“Th[e] [perpetration of a fraud] exception requires the party seeking enforcement of the contract to prove, at a minimum: (1) the performance of acts which constitute cogent evidence of the existence of the contract; (2) the terms of the contract by means of clear, cogent, unequivocal and convincing testimony; and (3) such a change in the party’s position as a result of the acts done in reliance on the contract that to permit the other party to avoid enforcement of the contract would result in a g

12
Lederle v. Lederlegreen
moctapp · 1996 · cited in 1 Missouri opinions naming this issue, 2025–2025
1 sentence

2025Johnson, 167 S.W.3d at 263 (citing Lederle v. Lederle, 916 S.W.2d 423, 428 (Mo. App. E.D. 1996)) (“Th[e] [perpetration of a fraud] exception requires the party seeking enforcement of the contract to prove, at a minimum: (1) the performance of acts which constitute cogent evidence of the existence of the contract; (2) the terms of the contract by means of clear, cogent, unequivocal and convincing testimony; and (3) such a change in the party’s position as a result of the acts done in reliance on the contract that to permit the other party to avoid enforcement of the contract would result in a g

11
Pointer v. Wardgreen
mo · 1968 · cited in 1 Missouri opinions naming this issue, 2025–2025
2 sentences

2025To meet the partial performance exception to the statute of frauds, three elements must be met: There must be proof: (1) of the performance of acts by the proponent which are cogent evidence of the existence of the pleaded contract; (2) of the terms of the verbal contract by clear, cogent, unequivocal and convincing testimony; and (3) that the acts, referred to in the first mentioned element, were done in reliance on the contract and that, as a result of the acts, the positions of the parties were so changed that to permit the other party to rely on the statute of frauds would result in a gros

2025Id.

11
Shumate v. Dugangreen
moctapp · 1996 · cited in 1 Missouri opinions naming this issue, 2025–2025
1 sentence

2025To meet the partial performance exception to the statute of frauds, three elements must be met: There must be proof: (1) of the performance of acts by the proponent which are cogent evidence of the existence of the pleaded contract; (2) of the terms of the verbal contract by clear, cogent, unequivocal and convincing testimony; and (3) that the acts, referred to in the first mentioned element, were done in reliance on the contract and that, as a result of the acts, the positions of the parties were so changed that to permit the other party to rely on the statute of frauds would result in a gros

11
Forney v. Missouri Bridge & Concrete, Inc.green
moctapp · 2003 · cited in 1 Missouri opinions naming this issue, 2005–2005
1 sentence

2005“The proper measure of damages in a case where an owner breaches a construction contract by preventing the contractor from performing the work is the contract price less the amount it would have cost the contractor to perform the contract.” Forney v. Mo. Bridge & Concrete, Inc., 112 S.W.3d 471, 474 (Mo.App.2003).

11
Oberhellmann v. Oberhellmanngreen
moctapp · 1997 · cited in 1 Missouri opinions naming this issue, 2003–2003
1 sentence

2003Oberhellmann v. Oberhellmann, 950 S.W.2d 487, 488 (Mo. App. E.D.1997) (“only a party to a suit *755 may appeal”).

11
Feigenspan v. Pencegreen
mo · 1943 · cited in 1 Missouri opinions naming this issue, 1991–1991
2 sentences

1991Specifically, in Feigenspan v. Pence, 350 Mo. 821 , 168 S.W.2d 1074, 1080 (1943), the Missouri Supreme Court allowed a remand on a specific performance claim to assess money damages instead, noting that the plaintiff “should not be deprived of all relief, for equity having become possessed of the case will not stop short of complete justice.” Id.

1991Specifically, in Feigenspan v. Pence, 350 Mo. 821 , 168 S.W.2d 1074, 1080 (1943), the Missouri Supreme Court allowed a remand on a specific performance claim to assess money damages instead, noting that the plaintiff “should not be deprived of all relief, for equity having become possessed of the case will not stop short of complete justice.” Id.

11
Thomas v. Stategreen
moctapp · 1974 · cited in 1 Missouri opinions naming this issue, 1981–1981
1 sentence

1981Thomas v. State, 516 S.W.2d 761, 765 (Mo.App.1974).

11
Standard Mill Work & Supply Co. v. Mississippi Steel & Iron Co.green
· 1949 · cited in 1 Missouri opinions naming this issue, 1978–1978
2 sentences

1978Standard Millwork & Supply Co. v. Mississippi Steel & Iron Co., 205 Miss. 96 , 38 So.2d 448, 451 (banc 1949).

1978Standard Millwork & Supply Co. v. Mississippi Steel & Iron Co., 205 Miss. 96 , 38 So.2d 448, 451 (banc 1949).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Missouri. Read the followed side critically anyway.

Also cited on this issue (6)

CaseCitedYears
Strickland v. Washington green
scotus · 1984
2 sentences

1996Id. at 688 , 104 S.Ct. at 2064 .

1996Id. at 688 , 104 S.Ct. at 2064 .

11996–1996
Gundaker v. Templer green
moctapp · 1977
1 sentence

1993Id. at 309 .

11993–1993
Sanders v. State green
mo · 1987
1 sentence

1993Id.

11993–1993
Tramell v. Adam neutral
mo · 1828
1 sentence

1979Although it is true that payment of earnest money will suffice to “bind a contract” for the sale of goods otherwise unenforceable under the statute of frauds, the doctrine of part performance through payment of earnest money alone is inapplicable to contracts for the sale of realty, Alonzo v. Laubert, 418 S.W.2d 94 (Mo.1967); Swearengin v. Stafford, 188 S.W. 97 (Mo.1916); Bean v. Valle, 2 Mo. 126 (1829).

11979–1979
Alonzo v. Laubert green
mo · 1967
1 sentence

1979Although it is true that payment of earnest money will suffice to “bind a contract” for the sale of goods otherwise unenforceable under the statute of frauds, the doctrine of part performance through payment of earnest money alone is inapplicable to contracts for the sale of realty, Alonzo v. Laubert, 418 S.W.2d 94 (Mo.1967); Swearengin v. Stafford, 188 S.W. 97 (Mo.1916); Bean v. Valle, 2 Mo. 126 (1829).

11979–1979
Dowdy v. Lincoln National Life Insurance Company green
moctapp · 1964
1 sentence

1975In Dowdy v. Lincoln National Life Insurance Company, 384 S.W.2d 282 (Mo.App. 1964) this court held, l.c. 286[7] that a count of plaintiff’s complaint against an insurance company on a group insurance policy issued to the Welfare Association of a labor union which in turn issued certain certificates of insurance under the group policy was erroneously dismissed by a trial court for failure to state a cause of action where the plaintiff alleged the existence of the policy, that she was the beneficiary thereof, the performance or waiver of conditions precedent on her part, the death of the insured

11975–1975

Where else courts name it

OH 352 (1986–2026) TX 203 (1961–2026) KS 84 (1990–2025) IL 62 (1891–2025) CT 58 (1909–2025) CA 58 (1919–2026) NY 53 (1903–2026) MS 48 (1988–2022) AL 36 (1975–2023) FL 35 (1963–2026) PA 32 (1912–2025) MI 32 (1920–2025) UT 30 (1982–2026) MD 24 (1884–2025) RI 23 (1970–2026) IN 21 (1894–2023) GA 20 (1977–2025) OR 16 (1929–2026) MT 15 (1944–2020) TN 14 (1915–2026) MO 14 (1975–2025) WA 14 (1924–2026) NJ 11 (1961–2023) IA 10 (1909–2025) WY 10 (1926–2026) DC 10 (1985–2024) MN 10 (1905–2007) WI 10 (1965–2024) NM 10 (1986–2023) VA 9 (1969–2018) NC 9 (1984–2022) SC 9 (1981–2025) KY 9 (1924–2022) MA 8 (1978–2024) AZ 8 (1966–2023) DE 8 (1999–2026) CO 8 (1940–2025) NE 7 (1894–2022) ND 6 (1974–2016) ME 5 (1947–2011) VT 5 (1972–2024) OK 4 (1937–2007) LA 4 (1895–2026) SD 4 (2005–2023) WV 4 (1995–2015) ID 3 (2009–2026) HI 2 (1967–2024) AR 2 (1989–1996) AK 2 (1970–2021) NV 2 (1950–2015) NH 2 (1988–1997)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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