Texas Codes

Tex. Prop. Code § 5.072 (2026)

Oral Agreements Prohibited

✓ current as of May 2026
Find cases: SyfertCases citing this section TX-LEGstatutes.capitol.texas.gov Justiaon Justia CornellLII Search CasesGoogle Scholar

Sec. 5.072. ORAL AGREEMENTS PROHIBITED. (a) An executory contract is not enforceable unless the contract is in writing and signed by the party to be bound or by that party's authorized representative.

(b) The rights and obligations of the parties to a contract are determined solely from the written contract, and any prior oral agreements between the parties are superseded by and merged into the contract.

(c) An executory contract may not be varied by any oral agreements or discussions that occur before or contemporaneously with the execution of the contract.

(d) The seller shall include in a separate document or in a provision of the contract a statement printed in 14-point boldfaced type or 14-point uppercase typewritten letters that reads substantially similar to the following:

THIS EXECUTORY CONTRACT REPRESENTS THE FINAL AGREEMENT BETWEEN THE SELLER AND PURCHASER AND MAY NOT BE CONTRADICTED BY EVIDENCE OF PRIOR, CONTEMPORANEOUS, OR SUBSEQUENT ORAL AGREEMENTS OF THE PARTIES. THERE ARE NO UNWRITTEN ORAL AGREEMENTS BETWEEN THE PARTIES.

____________________________
____________________________
(Date)
(Signature of Seller)
____________________________
____________________________
(Date)
(Signature of Purchaser)

(e) The seller's failure to provide the notice required by this section:

(1) is a false, misleading, or deceptive act or practice within the meaning of Section 17.46, Business & Commerce Code, and is actionable in a public or private suit brought under Subchapter E, Chapter 17, Business & Commerce Code; and

(2) entitles the purchaser to cancel and rescind the executory contract and receive a full refund of all payments made to the seller.

(f) Subsection (e) does not limit the purchaser's remedy against the seller for other false, misleading, or deceptive acts or practices actionable in a suit brought under Subchapter E, Chapter 17, Business & Commerce Code.

Added by Acts 2001, 77th Leg., ch. 693, Sec. 1, eff. Sept. 1, 2001.

Notes of Decisions
Cited in 16 cases (6 in the last 5 years), 2007–2026 · leading case: Burrus v. Reyes, 516 S.W.3d 170 (Tex. App. 2017).
Burrus v. Reyes, 516 S.W.3d 170 (Tex. App. 2017). · cites it 2× “072 of the Texas Property Code, which addresses contracts for deed, provides that an “executory contract is not enforceable unless the contract is in writing and signed by the party to be bound or by that party’s authorized representative.”
Rex Smith v. Kelly Davis & Amber Davis, 462 S.W.3d 604 (Tex. App. 2015). · cites it 2× “Tex. Prop. Code Ann. § 5.072 (a)-(c) (West 2004).”
Leorris Thomas v. Bobby Miller & Thyra Miller, 500 S.W.3d 601 (Tex. App. 2016). “” Tex. Prop. Code Ann. § 5.072 (a) (West 2014).”
Rex Smith v. Kelly Davis & Amber Davis (Tex. App. 2014). · cites it 6× “VOID EXECUTORY CONTRACT In their first issue, the Smiths claim that the executory contract is void because it violates Texas Property Code Section 5.072. Specifically, the Smiths argue in their brief that “the written agreement on which [the Davises] base their claims is void,…”
Jack Craig Effel v. Robert G. Rosberg (Tex. App. 2018). · cites it 2× “201 …………………………………………………………… 3, 10 STATEMENT REGARDING ORAL ARGUMENT Appellant has not requested oral argument and the case does not require it. However, should appellant later request oral argument, appellee reserves the right to present argument in response.”
Rex Smith v. Kelly Davis & Amber Davis (Tex. App. 2015). · cites it 3× “TEXAS PROPERTY CODE SECTION 5.072 – ENFORCEABILITY OF EXECUTORY CONTRACTS In their first, fourth, seventh, and tenth issues, the Smiths claim that the executory contract violates Section 5.”
Rex Smith v. Kelly Davis & Amber Davis (Tex. App. 2015). · cites it 2× “2 Texas Property Code §5.072 ..............”
Frederick Dawson Graham v. Dena Marie Turner (Tex. App. 2015). · cites it 2× “15 TEXAS PROPERTY CODE §5.072(a) . . . . . .”
Mark Haynes, Danielle Megan Haynes & Charles Edward Haynes v. Mario Molina & Charlene Molina, Individually & Dba Master Mech. A/C & Heating, Jorge Molina (Tex. App. 2021). “A contract for deed is an executory contract, which is subject to the statute of frauds and which “is not enforceable unless the contract is in writing and signed by the party to be bound or by that party’s authorized representative.”
in Re Kingman Holdings, LLC, as Tr. (Tex. App. 2021). “See TEX. PROP. CODE ANN. § 5.072(a) (“An executory contract is not enforceable unless the contract is in writing and signed by the party to be bound or by that party’s authorized representative.”
Raymond Kerley v. Kenneth M. Branscome & Darlene J. Branscome, Trs. of Kenneth M. Branscome & Darlene J. Branscome Trust (Tex. App. 2024). “Because his bank 2 It is undisputed that Kerley never had a written contract to purchase the property as required by the Texas Property Code. See TEX. PROP. CODE ANN.”
In the Matter of the Est. of Alvaro Morales AKA Alvaro Morales Licon v. the State of Texas (Tex. App. 2025). “” Tex. Prop. Code Ann. § 5.072 (a). The statute of frauds also requires that a contract for the sale of real estate be signed.”
— Tex. Prop. Code § 5.072(a) — 4 cases
Rex Smith v. Kelly Davis & Amber Davis (Tex. App. 2014). “VOID EXECUTORY CONTRACT In their first issue, the Smiths claim that the executory contract is void because it violates Texas Property Code Section 5.072. Specifically, the Smiths argue in their brief that “the written agreement on which [the Davises] base their claims is void,…”
Frederick Dawson Graham v. Dena Marie Turner (Tex. App. 2015). “15 TEXAS PROPERTY CODE §5.072(a) . . . . . .”
in Re Kingman Holdings, LLC, as Tr. (Tex. App. 2021). “See TEX. PROP. CODE ANN. § 5.072(a) (“An executory contract is not enforceable unless the contract is in writing and signed by the party to be bound or by that party’s authorized representative.”
Rex Smith v. Kelly Davis & Amber Davis (Tex. App. 2015). “TEXAS PROPERTY CODE SECTION 5.072 – ENFORCEABILITY OF EXECUTORY CONTRACTS In their first, fourth, seventh, and tenth issues, the Smiths claim that the executory contract violates Section 5.”
— Tex. Prop. Code § 5.072(d) — 2 cases
Rex Smith v. Kelly Davis & Amber Davis (Tex. App. 2015). “TEXAS PROPERTY CODE SECTION 5.072 – ENFORCEABILITY OF EXECUTORY CONTRACTS In their first, fourth, seventh, and tenth issues, the Smiths claim that the executory contract violates Section 5.”
Rex Smith v. Kelly Davis & Amber Davis (Tex. App. 2015). “2 Texas Property Code §5.072 ..............”
— Tex. Prop. Code § 5.072(e)(1) — 1 case
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.