305 N.Y. 48, 110 N.E.2d 551 (N.Y. 1953) (Court of Appeals of New York)
Crabtree v. Elizabeth Arden Sales Corp.
Can the Statute of Frauds' one-year provision be satisfied by reading multiple writings together—at least one of which is signed by the party to be charged—where parol evidence connects the documents but does not supply essential terms?
Under the Statute of Frauds, a memorandum sufficient to evidence an agreement not to be performed within one year need not be contained in a single document. Several writings may be read together to satisfy the statute if (1) at least one writing is signed by the party to be charged (or its authorized agent), (2) the writings, when taken together, state the essential terms of the contract with reasonable certainty (e.g., parties, subject matter, key terms such as duration and price), and (3) there is adequate connection among the writings. Parol evidence is admissible to show the connection and the parties' assent to the unsigned documents, but it cannot supply an essential term entirely absent from the writings.
Yes. The Statute of Frauds was satisfied by the combination of the signed payroll cards and the unsigned internal memorandum because, taken together, they identified the parties, the duration (two years), and the staged salary increases; parol evidence could be used to connect the documents but not to add terms. The court reversed the lower court's determination that the statute barred enforcement and upheld the enforceability of the agreement.
Crabtree is the leading New York case—widely influential nationally—on satisfying the Statute of Frauds with multiple writings. It teaches that courts may piece together internal business records (e.g., payroll cards) and unsigned memoranda if the assembled documents, at least one of which is signed, state the essential terms. The case also clarifies the limited role of parol evidence: admissible to connect writings, inadmissible to fill in essential terms. This approach aligns with modern doctrine reflected in the Restatement (Second) of Contracts § 132 and is frequently tested in law school and the bar exam to evaluate students' grasp of the Statute of Frauds' evidentiary function.