Oklahoma Statutes

Okla. Stat. tit. 12A, § 2-201 (2026)

Formal Requirements; Statute of Frauds

✓ current as of July 2026
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(1) Except as otherwise provided in this section, a contract for the sale of goods for the price of Five Hundred Dollars ($500.00) 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 paragraph 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 ten (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 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 (Section 2- 606). Added by Laws 1961, p. 77, § 2-201. Amended by Laws 2024, c. 13, § 7, eff. Nov. 1, 2024.

Notes of Decisions
Cited in 9 cases (1 in the last 5 years), 1975–2023 · leading case: Darrow v. Spencer, 581 P.2d 1309 (Okla. 1978).
Darrow v. Spencer, 581 P.2d 1309 (Okla. 1978). · cites it 4× “Darrow has appealed from the judgment in the trial court arguing that, among other things, that the Statute of Frauds’ provisions of the Uniform Commercial Code, set forth at 12A O.S.1971 § 2-201, prohibits the enforcement of the oral contract upon which the suit was based.”
United Gen. Ins. Co. v. Crane Carrier Co., 695 P.2d 1334 (Okla. 1984). “A plaintiff may also seek redress on a theory of breach of an implied warranty, if he pleads facts to bring him within the provisions of Article 2 of the Uniform Commercial Code, 12A O.S. 1971, §§ 2-201 to 2-725 ....” Citations omitted).”
Musket Corp. v. Star Fuel of Oklahoma, 606 F. App'x 439 (10th Cir. 2015). “” Okla. Stat. tit. 12A, § 2-201(1). This Court has recognized gasoline as a good that is subject to the statute of frauds.”
Cochran v. Buddy Spencer Mobile Homes, Inc., 618 P.2d 947 (Okla. Civ. App. 1980). “A plaintiff may also seek redress on a theory of breach of an implied warranty, if he pleads facts to bring him within the provisions of Article 2 of the Uniform Commercial Code, 12A O.S. 1971, §§ 2-201 to 2-725 (hereinafter cited by U.”
Dixon v. Roberts, 853 P.2d 235 (Okla. Civ. App. 1993). · cites it 2× “He cites 12A O.S. 1991 § 2-201(1). However, while Appellant’s answer generally pled the defense of the statute of frauds, among a general generic list of defenses, it was not otherwise argued in the trial court.”
Shipman v. Craig Ayers Chevrolet, Inc., 541 P.2d 876 (Okla. Civ. App. 1975). “There is no evidence of any voluntary rescission on the part of the plaintiff, but on the contrary, the evidence is conclusive that plaintiff never intended to rescind at any time.”
Thomas P. Gibson v. L.D. \Poke\" Arnold, 288 F.3d 1242 (2002). “See Okla. Stat. Ann. tit. 12A, § 2-201(3)(b); see also Darrow, 581 P.”
Trillium Transp. Fuels LLC v. Integral Energy LLC (W.D. Okla. 2023). “22 See Okla. Stat. tit. 12A, § 2-201(1); Fla. Stat.”
Musket Corp. v. Star Fuel of Oklahoma, LLC, 943 F. Supp. 2d 1304 (W.D. Okla. 2013). “Okla. Stat. tit. 12A, § 2-201(1). Additionally, under Oklahoma law, “an implied contract .”
— Okla. Stat. tit. 12A, § 2-201(1) — 4 cases
Musket Corp. v. Star Fuel of Oklahoma, 606 F. App'x 439 (10th Cir. 2015). “” Okla. Stat. tit. 12A, § 2-201(1). This Court has recognized gasoline as a good that is subject to the statute of frauds.”
Dixon v. Roberts, 853 P.2d 235 (Okla. Civ. App. 1993). “He cites 12A O.S. 1991 § 2-201(1). However, while Appellant’s answer generally pled the defense of the statute of frauds, among a general generic list of defenses, it was not otherwise argued in the trial court.”
Trillium Transp. Fuels LLC v. Integral Energy LLC (W.D. Okla. 2023). “22 See Okla. Stat. tit. 12A, § 2-201(1); Fla. Stat.”
Musket Corp. v. Star Fuel of Oklahoma, LLC, 943 F. Supp. 2d 1304 (W.D. Okla. 2013). “Okla. Stat. tit. 12A, § 2-201(1). Additionally, under Oklahoma law, “an implied contract .”
— Okla. Stat. tit. 12A, § 2-201(2) — 1 case
Dixon v. Roberts, 853 P.2d 235 (Okla. Civ. App. 1993). “He cites 12A O.S. 1991 § 2-201(1). However, while Appellant’s answer generally pled the defense of the statute of frauds, among a general generic list of defenses, it was not otherwise argued in the trial court.”
— Okla. Stat. tit. 12A, § 2-201(3) — 2 cases
Darrow v. Spencer, 581 P.2d 1309 (Okla. 1978). “Darrow has appealed from the judgment in the trial court arguing that, among other things, that the Statute of Frauds’ provisions of the Uniform Commercial Code, set forth at 12A O.S.1971 § 2-201, prohibits the enforcement of the oral contract upon which the suit was based.”
Shipman v. Craig Ayers Chevrolet, Inc., 541 P.2d 876 (Okla. Civ. App. 1975). “There is no evidence of any voluntary rescission on the part of the plaintiff, but on the contrary, the evidence is conclusive that plaintiff never intended to rescind at any time.”
— Okla. Stat. tit. 12A, § 2-201(3)(b) — 1 case
Thomas P. Gibson v. L.D. \Poke\" Arnold, 288 F.3d 1242 (2002). “See Okla. Stat. Ann. tit. 12A, § 2-201(3)(b); see also Darrow, 581 P.”
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