part performance doctrine (North Dakota) · Go Syfert
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part performance doctrine in North Dakota

7 North Dakota opinions name it 1 courts 1903–2021 1 in the last five years

The cases below were cited by North Dakota 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 (8)

CaseFollowedCited
Hofmann v. Stollergreen
nd · 1982 · cited in 2 North Dakota opinions naming this issue, 2011–2011
2 sentences

2011Hofmann , at 790-91.

2011Hofmann , at 790-91.

22
Williston Cooperative Credit Union v. Fossumgreen
nd · 1990 · cited in 1 North Dakota opinions naming this issue, 2021–2021
1 sentence

2021Thus, part payment of the purchase price and substantial improvements to the property may remove an oral contract from the statute of frauds and create an enforceable contract constituting an enforceable equitable property interest.” Williston Co-Op Credit Union v. Fossum, 459 N.W.2d 548, 551 (N.D. 1990) (emphasis added). [¶16] The Schirados’ remaining three arguments arise under the doctrine of part performance.

11
Cooke v. Blood Systems, Inc.green
nd · 1982 · cited in 1 North Dakota opinions naming this issue, 1998–1998
1 sentence

1998Felco responds there was no oral agreement to forgive past due rent and argues the trial court should have decided this question as a matter of law because the alleged agreement to forgive over $50,000 in past due percentage rent was not in writing as required by N.D.C.C. § 9-06-04(5), which provides “[a]n agreement or promise to alter the terms of repayment or forgiveness of a debt that is in an aggregate amount of twenty-five thousand dollars or greater” must be “in writing and subscribed by the party to be charged.” Doug’s, however, argues the doctrine of part performance “is a bar to the a

11
Vasichek v. Thorsengreen
nd · 1978 · cited in 1 North Dakota opinions naming this issue, 1997–1997
2 sentences

1997See also Restatement of Contracts (First) § 197 (1932) (part performance satisfied if purchaser “(a) makes valuable improvements on the land, or (b) takes possession thereof or retains a possession thereof existing at the time of the bargain, and also pays a portion or all of the purchase price”); Breen v. Phelps, 186 Conn. 86 , 439 A.2d 1066, 1074 (1982) (possession is not a prerequisite for part performance, but “may be highly significant in establishing the reasonable reliance upon the oral contract which is essential”); Powell, ¶ 880[2][c][i], at p. 81-70 (“To be sufficient under the doctr

1997See also Restatement of Contracts (First) § 197 (1932) (part performance satisfied if purchaser “(a) makes valuable improvements on the land, or (b) takes possession thereof or retains a possession thereof existing at the time of the bargain, and also pays a portion or all of the purchase price”); Breen v. Phelps, 186 Conn. 86 , 439 A.2d 1066, 1074 (1982) (possession is not a prerequisite for part performance, but “may be highly significant in establishing the reasonable reliance upon the oral contract which is essential”); Powell, ¶ 880[2][c][i], at p. 81-70 (“To be sufficient under the doctr

11
Breen v. Phelpsgreen
conn · 1982 · cited in 1 North Dakota opinions naming this issue, 1997–1997
2 sentences

1997See also Restatement of Contracts (First) § 197 (1932) (part performance satisfied if purchaser “(a) makes valuable improvements on the land, or (b) takes possession thereof or retains a possession thereof existing at the time of the bargain, and also pays a portion or all of the purchase price”); Breen v. Phelps, 186 Conn. 86 , 439 A.2d 1066, 1074 (1982) (possession is not a prerequisite for part performance, but “may be highly significant in establishing the reasonable reliance upon the oral contract which is essential”); Powell, ¶ 880[2][c][i], at p. 81-70 (“To be sufficient under the doctr

1997See also Restatement of Contracts (First) § 197 (1932) (part performance satisfied if purchaser “(a) makes valuable improvements on the land, or (b) takes possession thereof or retains a possession thereof existing at the time of the bargain, and also pays a portion or all of the purchase price”); Breen v. Phelps, 186 Conn. 86 , 439 A.2d 1066, 1074 (1982) (possession is not a prerequisite for part performance, but “may be highly significant in establishing the reasonable reliance upon the oral contract which is essential”); Powell, ¶ 880[2][c][i], at p. 81-70 (“To be sufficient under the doctr

11
Miller v. McCamishgreen
wash · 1971 · cited in 1 North Dakota opinions naming this issue, 1981–1981
2 sentences

1981The North Dakota Supreme Court discussed the doctrine of part performance in Buettner v. Nostdahl, 204 N.W.2d 187, 195 (N.D.1973) [wherein the Washington case of Miller v. McCamish, 78 Wash.2d 821 , 479 P.2d 919 at 923, 924 (1971), quoted from an earlier Washington case, Granquist v. McKean, 29 Wash.2d 440, 445 , 187 P.2d 623, 626 (1947)] as enunciated in the Washington court to the effect that a contract to be exempted from the statute of frauds must be proven by evidence that is clear and unequivocal and which leaves no doubt as to the terms, character, and existence of the contract; and it

1981The North Dakota Supreme Court discussed the doctrine of part performance in Buettner v. Nostdahl, 204 N.W.2d 187, 195 (N.D.1973) [wherein the Washington case of Miller v. McCamish, 78 Wash.2d 821 , 479 P.2d 919 at 923, 924 (1971), quoted from an earlier Washington case, Granquist v. McKean, 29 Wash.2d 440, 445 , 187 P.2d 623, 626 (1947)] as enunciated in the Washington court to the effect that a contract to be exempted from the statute of frauds must be proven by evidence that is clear and unequivocal and which leaves no doubt as to the terms, character, and existence of the contract; and it

11
Buettner v. Nostdahlgreen
nd · 1973 · cited in 1 North Dakota opinions naming this issue, 1981–1981
1 sentence

1981The North Dakota Supreme Court discussed the doctrine of part performance in Buettner v. Nostdahl, 204 N.W.2d 187, 195 (N.D.1973) [wherein the Washington case of Miller v. McCamish, 78 Wash.2d 821 , 479 P.2d 919 at 923, 924 (1971), quoted from an earlier Washington case, Granquist v. McKean, 29 Wash.2d 440, 445 , 187 P.2d 623, 626 (1947)] as enunciated in the Washington court to the effect that a contract to be exempted from the statute of frauds must be proven by evidence that is clear and unequivocal and which leaves no doubt as to the terms, character, and existence of the contract; and it

11
Granquist v. McKeangreen
wash · 1947 · cited in 1 North Dakota opinions naming this issue, 1981–1981
2 sentences

1981The North Dakota Supreme Court discussed the doctrine of part performance in Buettner v. Nostdahl, 204 N.W.2d 187, 195 (N.D.1973) [wherein the Washington case of Miller v. McCamish, 78 Wash.2d 821 , 479 P.2d 919 at 923, 924 (1971), quoted from an earlier Washington case, Granquist v. McKean, 29 Wash.2d 440, 445 , 187 P.2d 623, 626 (1947)] as enunciated in the Washington court to the effect that a contract to be exempted from the statute of frauds must be proven by evidence that is clear and unequivocal and which leaves no doubt as to the terms, character, and existence of the contract; and it

1981The North Dakota Supreme Court discussed the doctrine of part performance in Buettner v. Nostdahl, 204 N.W.2d 187, 195 (N.D.1973) [wherein the Washington case of Miller v. McCamish, 78 Wash.2d 821 , 479 P.2d 919 at 923, 924 (1971), quoted from an earlier Washington case, Granquist v. McKean, 29 Wash.2d 440, 445 , 187 P.2d 623, 626 (1947)] as enunciated in the Washington court to the effect that a contract to be exempted from the statute of frauds must be proven by evidence that is clear and unequivocal and which leaves no doubt as to the terms, character, and existence of the contract; and it

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (2)

CaseCitedYears
Nasanowitz v. Hane neutral
nyappterm · 1896
1 sentence

1903The doctrine of part performance applies only where a contract is so far performed that the parties cannot be restored to their original position except by equitable aid, which is sometimes extended to prevent fraud.” See, also, Nasanowitz v. Hanf (Sup.) 39 N. Y.

11903–1903
Dunckel v. . Dunckel neutral
ny · 1894
2 sentences

1903Supp. 327 ; Dunckel v. Dunckel, 141 N. Y. 427 , 36 N. E. 405 ; Frye on Spec.

1903Supp. 327 ; Dunckel v. Dunckel, 141 N. Y. 427 , 36 N. E. 405 ; Frye on Spec.

11903–1903

Where else courts name it

NY 55 (1951–2025) WA 23 (1925–2022) CT 20 (1981–2014) OH 19 (1981–2025) AL 18 (1942–2011) ID 17 (1982–2023) IN 16 (1892–2025) UT 13 (1977–2022) ME 12 (2004–2020) MO 11 (1891–2025) AZ 11 (1977–2025) FL 9 (1974–2024) MI 9 (1917–2023) MD 9 (1939–1998) IL 8 (1986–2025) CA 8 (1930–2024) ND 7 (1903–2021) CO 7 (1983–2005) MN 6 (1909–2016) SC 6 (1984–2022) PA 6 (1982–2026) TN 6 (1983–2011) OR 6 (1975–2008) WI 5 (1945–2024) RI 5 (1991–2011) TX 5 (1967–2015) IA 5 (1939–2014) NC 5 (1920–2010) WY 4 (1993–2012) VA 4 (1851–2005) MT 3 (1926–2017) SD 3 (1912–2018) NJ 3 (1986–2013) DC 3 (1984–1998) NH 3 (2008–2017) DE 3 (1975–2019) VT 3 (1986–2015) GA 2 (2019–2022) KS 2 (1930–2018) KY 2 (1935–1947) NV 2 (1985–2018) NM 2 (2010–2021) VI 2 (1977–2025)

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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