Florida Statute 672.201 - Full Text and Legal Analysis

The 2025 Florida Statutes

Title XXXIX
COMMERCIAL RELATIONS

Chapter 672
UNIFORM COMMERCIAL CODE: SALES

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F.S. 672.201

672.201 Formal requirements; statute of frauds.—

(1) Except as otherwise provided in this section a contract for the sale of goods for the price of $500 or more is not enforceable by way of action or defense unless there is a record sufficient to indicate that a contract for sale has been made between the parties and signed by the party against whom enforcement is sought or by the party’s authorized agent or broker. A record is not insufficient because it omits or incorrectly states a term agreed upon, but the contract is not enforceable under this subsection beyond the quantity of goods shown in the record.

(2) Between merchants if within a reasonable time a record in confirmation of the contract and sufficient against the sender is received and the party receiving it has reason to know its contents, it satisfies the requirements of subsection (1) against the party unless notice in a record of objection to its contents is given within 10 days after it is received.

(3) A contract which does not satisfy the requirements of subsection (1) but which is valid in other respects is enforceable:

(a) If the goods are to be specially manufactured for the buyer and are not suitable for sale to others in the ordinary course of the seller’s business and the seller, before notice of repudiation is received and under circumstances which reasonably indicate that the goods are for the buyer, has made either a substantial beginning of their manufacture or commitments for their procurement; or

(b) If the party against whom enforcement is sought admits in his or her pleading, testimony or otherwise in court that a contract for sale was made, but the contract is not enforceable under this provision beyond the quantity of goods admitted; or

(c) With respect to goods for which payment has been made and accepted or which have been received and accepted (s. 672.606).

History.—s. 1, ch. 65-254; s. 557, ch. 97-102; s. 42, ch. 2025-92.

Note.—s. 2-201, U.C.C.

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Amendments to 672.201

Annotations, Discussions, Cases:

Cases Citing Statute 672.201

Total Results: 36

Contractors & Builders Ass'n v. City of Dunedin

329 So. 2d 314, 1976 Fla. LEXIS 4301

Supreme Court of Florida | Filed: Feb 25, 1976 | Docket: 1251225

Cited 89 times | Published

goods for the price of $500 or more", Fla. Stat. § 672.201 (1973), is unenforceable unless reduced to writing

Ashland Oil, Inc. v. Pickard

269 So. 2d 714

District Court of Appeal of Florida | Filed: Nov 28, 1972 | Docket: 1258290

Cited 59 times | Published

agreement not to be performed within one year, and § 672.201 Fla. Stat., F.S.A., requiring a written memorandum

Mettler, Inc. v. Ellen Tracy, Inc.

648 So. 2d 253, 1994 WL 717899

District Court of Appeal of Florida | Filed: Dec 30, 1994 | Docket: 1342951

Cited 21 times | Published

face, would violate the statute of frauds. See § 672.201(1), Fla. Stat. (1991).

Boldstar Technical, LLC v. Home Depot, Inc.

517 F. Supp. 2d 1283, 2007 U.S. Dist. LEXIS 79723, 2007 WL 3071408

District Court, S.D. Florida | Filed: Oct 3, 2007 | Docket: 109601

Cited 14 times | Published

been memorialized in a writing. See Fla. Stat. § 672.201(1). While the statute by its terms bars recovery

White Construction Co. v. Martin Marietta Materials, Inc.

633 F. Supp. 2d 1302, 2009 U.S. Dist. LEXIS 29467, 2009 WL 961135

District Court, M.D. Florida | Filed: Apr 7, 2009 | Docket: 1266875

Cited 8 times | Published

Commercial Code Statute of Frauds, Fla. Stat. § 672.201. Pursuant to that section: a contract for the

Conner, I, Inc. v. Walt Disney Co.

827 So. 2d 318, 2002 Fla. App. LEXIS 13214, 2002 WL 31039451

District Court of Appeal of Florida | Filed: Sep 13, 2002 | Docket: 1726362

Cited 7 times | Published

GRIFFIN and SAWAYA, JJ., concur. NOTES [1] § 672.201, Fla. Stat. (1996). [2] § 672.206, Fla. Stat

Packaging Corp. International v. Travenol Laboratories, Inc.

566 F. Supp. 1480, 1983 U.S. Dist. LEXIS 15370

District Court, S.D. Florida | Filed: Jul 18, 1983 | Docket: 2241846

Cited 7 times | Published

writing in order to be enforceable. See Fla.Stat. § 672.201(1) (1978).[4] The contract in the case at bar

Technical Packaging, Inc. v. Hanchett

992 So. 2d 309, 2008 WL 4366038

District Court of Appeal of Florida | Filed: Sep 26, 2008 | Docket: 1723137

Cited 6 times | Published

of the Uniform Commercial Code. See generally § 672.201, Fla. Stat. (2002); 45 Fla. Jur.2d Sales and Exchanges

Topp, Inc. v. Uniden American Corp.

483 F. Supp. 2d 1187, 2007 U.S. Dist. LEXIS 31204, 2007 WL 1119192

District Court, S.D. Florida | Filed: Mar 30, 2007 | Docket: 2204549

Cited 6 times | Published

R & R's analysis, arguing that (1) Fla. Stat. § 672.201 applies to its claims and thus there is a quantity

OFFICE PAVILION SO. FLA. v. ASAL Products, Inc.

849 So. 2d 367, 2003 WL 21180126

District Court of Appeal of Florida | Filed: May 21, 2003 | Docket: 1509321

Cited 6 times | Published

adopted from the Uniform Commercial Code. Section 672.201(1), Florida Statutes (1997), provides that

Centro Nautico v. INTERN. MARINE CO-OP

719 So. 2d 967, 1998 WL 712696

District Court of Appeal of Florida | Filed: Oct 14, 1998 | Docket: 1352037

Cited 4 times | Published

evidence or legal theory supports this award. UCC section 672.201 limits enforcement of oral contracts captured

Jim & Slim's Tool Supply, Inc. v. METRO COMMUN. CORP.

328 So. 2d 213, 19 U.C.C. Rep. Serv. (West) 77

District Court of Appeal of Florida | Filed: Mar 10, 1976 | Docket: 1699690

Cited 4 times | Published

Frauds" provision of the Uniform Commercial Code, § 672.201, F.S. 1973, in that it is an oral contract for

Furr v. Corvette Experience, Inc. (In Re Corvette Collection of Boston, Inc.)

294 B.R. 409, 16 Fla. L. Weekly Fed. B 143, 51 U.C.C. Rep. Serv. 2d (West) 426, 50 Collier Bankr. Cas. 2d 743, 2003 Bankr. LEXIS 590

United States Bankruptcy Court, S.D. Florida. | Filed: Jun 11, 2003 | Docket: 1804642

Cited 3 times | Published

and barred by the Statute of Frauds. Fla. Stat. § 672.201 states: Except as otherwise provided in this section

United States v. Conrad

619 F. Supp. 1319, 42 U.C.C. Rep. Serv. (West) 424, 1985 U.S. Dist. LEXIS 14972

District Court, M.D. Florida | Filed: Oct 11, 1985 | Docket: 2509863

Cited 3 times | Published

upon does not satisfy the statute of frauds, Section 672.201, Florida Statutes (1983). This case was tried

ADV. MOBILEHOME SYS. v. Alumax

666 So. 2d 166

District Court of Appeal of Florida | Filed: Nov 8, 1995 | Docket: 1510883

Cited 2 times | Published

reasonable time after notice of them is received. Section 672.201 is not applicable here. It deals solely with

Bakst v. Wheeler Oil Co. (In Re Denmark Co.)

73 B.R. 325, 4 U.C.C. Rep. Serv. 2d (West) 68, 1987 Bankr. LEXIS 679

United States Bankruptcy Court, S.D. Florida. | Filed: Apr 3, 1987 | Docket: 1846337

Cited 2 times | Published

statute of frauds section, 2-201 (Fla.Stat. § 672.201) requires the production of a written consignment

B & C Investors, Inc. v. Vojak

79 So. 3d 42, 2011 Fla. App. LEXIS 12445, 2011 WL 3477163

District Court of Appeal of Florida | Filed: Aug 10, 2011 | Docket: 60305328

Cited 1 times | Published

as a tort action.” See id. at 1289 (citing section 672.201(1), Florida Statutes, for the proposition that

Ge Lin v. Ecclestone Signature Homes of Palm Beach, LLC

59 So. 3d 267, 74 U.C.C. Rep. Serv. 2d (West) 293, 2011 Fla. App. LEXIS 5206, 2011 WL 1376686

District Court of Appeal of Florida | Filed: Apr 13, 2011 | Docket: 1913699

Cited 1 times | Published

writing, violating the statute of frauds, section 672.201, Florida Statutes, which required that the

Business Radio, Inc. v. Relm Wireless Corp.

373 F. Supp. 2d 1317, 2005 U.S. Dist. LEXIS 17770, 2005 WL 1432788

District Court, M.D. Florida | Filed: Jun 20, 2005 | Docket: 2140226

Cited 1 times | Published

such a claim. The Statute of Frauds, FLA. STAT. § 672.201(1) or WASH. REV. CODE § 62A.2-201, generally provides

American Zurich Insurance Co. v. St. George Crystal, Ltd.

870 So. 2d 243, 2004 Fla. App. LEXIS 3882, 2004 WL 592426

District Court of Appeal of Florida | Filed: Mar 26, 2004 | Docket: 64829658

Cited 1 times | Published

agreement was a contract for the sale of goods, section 672.201, Florida Statutes (1997), the statute of frauds

Khoshnou v. PAINE, WEBBER, JACKSON ETC.

525 So. 2d 977, 6 U.C.C. Rep. Serv. 2d (West) 187, 13 Fla. L. Weekly 1217, 1988 Fla. App. LEXIS 2071, 1988 WL 48804

District Court of Appeal of Florida | Filed: May 19, 1988 | Docket: 1710638

Cited 1 times | Published

law, and that it is to be interpreted like section 672.201(2), the Statute of Frauds provision regarding

Rozema v. Wilson

419 So. 2d 1139, 34 U.C.C. Rep. Serv. (West) 1506

District Court of Appeal of Florida | Filed: Sep 23, 1982 | Docket: 1584919

Cited 1 times | Published

and fell within the UCC Statute of Frauds, Section 672.201, Florida Statutes. Moreover, she claimed the

Isaac Industries, Inc. v. Bariven S.A.

Court of Appeals for the Eleventh Circuit | Filed: Jan 24, 2025 | Docket: 68035424

Published

Argued: Dec 10, 2024

whom enforcement is sought.” FLA. STAT. § 672.201(1) (2024). But the statute exempts contracts “[w]ith

Tm Wireless Communication Services v. All Commerce

246 So. 3d 541

District Court of Appeal of Florida | Filed: May 16, 2018 | Docket: 6716284

Published

induce TM Wireless to buy the telephones. See § 672.201(1), Fla. Stat. (2013) (“[A] contract for the

Branch Banking & Trust Co. v. M/Y Beowulf

883 F. Supp. 2d 1199, 2012 WL 2064570, 2012 U.S. Dist. LEXIS 79138

District Court, S.D. Florida | Filed: Jun 7, 2012 | Docket: 65984035

Published

statute of frauds provided in Article 2 of the UCC, § 672.201, requiring “some writing sufficient to indicate

HPBC, INC. v. Nor-Tech Powerboats, Inc.

946 So. 2d 1108, 2006 WL 3524019

District Court of Appeal of Florida | Filed: Dec 8, 2006 | Docket: 1771628

Published

authorized. Florida's Uniform Commercial Code, section 672.201(1), Florida Statutes (2005), provides: Except

Advanced Mobilehome Systems of Tampa, Inc. v. Alumax Fabricated Products, Inc.

666 So. 2d 166, 28 U.C.C. Rep. Serv. 2d (West) 91, 1995 Fla. App. LEXIS 11675

District Court of Appeal of Florida | Filed: Nov 8, 1995 | Docket: 64761291

Published

reasonable time after notice of them is received. Section 672.201 is not applicable here. It deals solely with

Spaziani v. Bancroft

618 So. 2d 744, 1993 Fla. App. LEXIS 4515, 1993 WL 125160

District Court of Appeal of Florida | Filed: Apr 23, 1993 | Docket: 64696424

Published

identifies the party to be charged. 19A F.S.A. p. 121, § 672.201 UCC cmt. 1 (1978). The comment to the general

In Re Atkins

139 B.R. 39, 19 U.C.C. Rep. Serv. 2d (West) 18, 6 Fla. L. Weekly Fed. B 83, 1992 Bankr. LEXIS 589, 1992 WL 78046

United States Bankruptcy Court, M.D. Florida | Filed: Apr 14, 1992 | Docket: 1111464

Published

quantity of goods shown in such writing. Fla.Stat. § 672.201. In order to promote accuracy and certainty in

In re Hastings Marine Corp.

99 B.R. 98, 1989 Bankr. LEXIS 625, 1989 WL 41923

United States Bankruptcy Court, M.D. Florida | Filed: Apr 24, 1989 | Docket: 65779781

Published

equivalent to a consignment agreement. Fla.Stat. § 672.201 governs written consignment agreements. This section

In re Hastings Marine Corp.

99 B.R. 98, 1989 Bankr. LEXIS 625, 1989 WL 41923

United States Bankruptcy Court, M.D. Florida | Filed: Apr 24, 1989 | Docket: 65779781

Published

equivalent to a consignment agreement. Fla.Stat. § 672.201 governs written consignment agreements. This section

J.R. Sales, Inc. v. Dicks

521 So. 2d 366, 13 Fla. L. Weekly 655, 1988 Fla. App. LEXIS 1058, 1988 WL 20645

District Court of Appeal of Florida | Filed: Mar 10, 1988 | Docket: 64633203

Published

statutory exceptions to the writing requirement. Section 672.201(3), Florida Statutes (1985); Lea Industries

Al Booth's, Inc. v. Boyd-Scarp Enterprises Inc.

518 So. 2d 422, 13 Fla. L. Weekly 147, 1988 Fla. App. LEXIS 25, 1988 WL 205

District Court of Appeal of Florida | Filed: Jan 7, 1988 | Docket: 64631992

Published

The statute of frauds found in the U.C.C., section 672.201, Florida Statutes (1985), is not a defense

Driver v. Ford (In Re Driver)

78 B.R. 616, 5 U.C.C. Rep. Serv. 2d (West) 1281, 1987 Bankr. LEXIS 2206

United States Bankruptcy Court, M.D. Florida | Filed: Oct 20, 1987 | Docket: 1801185

Published

the Statute of Frauds provisions contained in § 672.201, Florida Statutes, would bar enforcement of the

La Rosa v. Fortier

492 So. 2d 425, 11 Fla. L. Weekly 1607

District Court of Appeal of Florida | Filed: Jul 23, 1986 | Docket: 1518600

Published

of frauds and is therefore unenforceable. Section 672.201(1), Florida Statutes (1983), provides in relevant

Miami Purveyors, Inc. v. Forte

407 So. 2d 330, 1981 Fla. App. LEXIS 22003

District Court of Appeal of Florida | Filed: Dec 15, 1981 | Docket: 64586773

Published

Forte’s agreement was unenforceable under either Section 672.201 or Section 725.01, Florida Statutes (1977)