Master Classic Statute of Frauds case limiting recovery to restitution and denying reliance damages when an oral agreement within the statute is unenforceable and the defendant received no benefit. with this comprehensive case brief.
Boone v. Coe is a foundational Statute of Frauds case taught in Contracts courses to illustrate the limits of damages when an oral agreement is unenforceable. The case draws a bright line between restitutionary recovery for benefits conferred and reliance damages for losses incurred in preparing to perform. Boone teaches that courts will not allow disappointed parties to obtain damages that would indirectly enforce an unwritten agreement that the Statute of Frauds declares unenforceable.
The case is especially important for understanding the relationship among expectation, reliance, and restitution interests. It underscores that, absent a writing or a recognized exception, a plaintiff cannot recover either the benefit of the bargain or preparation expenses if the defendant has received no benefit. Boone thus frames the strategic and evidentiary importance of memorializing agreements within the Statute of Frauds and highlights the policy choice to prevent circumvention of the statute through tort-like or quasi-contract damages that replicate contractual enforcement.
Boone v. Coe, 153 Ky. 233, 154 S.W. 900 (Ky. 1913)
Plaintiffs, members of the Boone family residing in Kentucky, entered into an oral agreement with defendant Coe concerning a farm in Texas. Coe orally promised to provide plaintiffs with a one-year lease and a dwelling house on his Texas land, to begin at a future date, so that plaintiffs could relocate their families and farm the land under agreed terms. Relying on Coe’s promises, plaintiffs uprooted from Kentucky, transported themselves and their belongings to Texas, and incurred substantial expenses and lost time and earnings in the process. When they arrived, Coe did not furnish the promised house or leasehold and refused to perform the agreement. Plaintiffs sued in Kentucky seeking damages including travel and relocation expenses, lost time, and anticipated profits. Coe invoked the Statute of Frauds, arguing the agreement, being for an interest in land and not performable within one year from its making, was unenforceable absent a signed writing. The trial court allowed recovery, and Coe appealed.
May a plaintiff recover reliance damages for expenses and losses incurred in preparing to perform an oral agreement that falls within the Statute of Frauds, where the defendant has received no benefit from the plaintiff’s actions?
Agreements within the Statute of Frauds, including leases or interests in land for a term not to be performed within one year and agreements not performable within one year from their making, are unenforceable absent a signed writing. When such an oral agreement is unenforceable, the plaintiff may not recover expectation or reliance damages that would indirectly enforce the contract. Recovery, if any, is limited to restitution for the reasonable value of benefits conferred on and accepted by the defendant to prevent unjust enrichment; where the defendant received no benefit, no recovery lies.
No. Because the oral agreement fell within the Statute of Frauds and the defendant received no benefit from the plaintiffs’ preparations, plaintiffs could not recover expectation or reliance damages. With no benefit conferred on the defendant, restitution was unavailable, and the action failed.
The court first determined the oral agreement was within the Statute of Frauds because it concerned an interest in land and was not to be performed within one year from its making, as the one-year lease was to commence in the future. Without a signed writing containing the essential terms, the agreement was unenforceable. The court then rejected plaintiffs’ attempt to recover relocation expenses, lost time, and anticipated profits. Awarding such damages would operate as an indirect enforcement of an agreement the statute deems unenforceable, undermining the statute’s purpose of preventing fraud and perjury in proof of significant contracts. The court emphasized the distinction between enforcing an agreement and preventing unjust enrichment: while restitution is sometimes available notwithstanding the Statute of Frauds, it is limited to the value of benefits actually conferred on and retained by the defendant. Here, plaintiffs’ expenses and lost time were incurred for their own preparations and yielded no benefit to Coe; he received nothing of value from their move. To allow recovery of those expenditures would be to enforce the very bargain the statute bars. The court also noted that doctrines like part performance do not justify damages at law on these facts because there was no performance of the land agreement itself (such as possession or improvements), and in any event equitable exceptions are narrowly tailored and do not extend to compensating preparatory reliance where the defendant has not been enriched.
Boone v. Coe is a cornerstone case showing that when the Statute of Frauds renders an oral contract unenforceable, plaintiffs cannot use reliance damages as an end-run around the statute. It sharpens the doctrinal boundaries between expectation, reliance, and restitution, and it is frequently contrasted with cases permitting quantum meruit when the defendant is unjustly enriched. For students, Boone highlights the need for a writing for agreements within the Statute of Frauds and provides a cautionary example that preparatory expenditures are not recoverable absent a recognized exception or an actual benefit conferred on the defendant.
The agreement involved a one-year lease of land to commence in the future, placing it within two classic Statute of Frauds categories: an interest in land and an agreement not performable within one year from its making. Kentucky’s statute required a signed writing for such agreements. Because there was no adequate writing, the contract was unenforceable.
No. The court held that allowing reliance damages would indirectly enforce an oral agreement the statute makes unenforceable. Reliance damages compensate for preparation and performance costs, but Boone restricts recovery to restitution for benefits conferred on the defendant. Since Coe received no benefit from the plaintiffs’ move, there was nothing to restore.
Sometimes. Boone permits restitution to prevent unjust enrichment where the defendant received and retained a benefit (for example, services or improvements). But absent a conferred benefit, there is no restitution, and expectation or reliance damages are unavailable.
Not on these facts. The plaintiffs never took possession or improved the land, and their actions were preparatory rather than performance of the land agreement. Boone indicates that equitable doctrines like part performance are limited and do not authorize damages at law for reliance where the defendant has not been enriched. Modern courts in some jurisdictions may consider promissory estoppel to avoid the Statute of Frauds, but Boone predates that development and does not apply it.
A signed memorandum by the party to be charged (Coe) that identified the parties, the property, the lease term and commencement date, and the essential financial terms (e.g., rent or share). Even a series of writings taken together can suffice if they collectively contain the essential terms and are signed by the party to be charged.
Boone v. Coe stands for a clear and oft-tested proposition: courts will not award damages that effectively enforce an oral agreement the Statute of Frauds renders unenforceable. Plaintiffs who incur costs in anticipation of such an agreement bear the risk of nonrecovery unless they can show the defendant actually received and retained a benefit that equity requires be restored.
For practitioners and students, Boone underscores two practical lessons. First, reduce agreements within the Statute of Frauds to a signed writing that sets out essential terms. Second, in litigation, carefully distinguish between enforcing the bargain (expectation or reliance) and preventing unjust enrichment (restitution), recognizing that Boone allows only the latter and only where a real benefit has been conferred.