Statute of Frauds Unsatisfied

Copano Energy v. Bujnoch presents the application of a 343-year-old rule, the Statute of Frauds, with modern business based on the exchange of emails. Here: “The e-mails containing many of the alleged deal’s principal terms are part of a forward-looking request to negotiate a contract. Neither those e-mails nor any other writing evidences the defendant’s agreement to the particular terms stated in the e-mails. As a result, there is no ‘written memorandum which is complete within itself in every material detail,’ as required by the statute of frauds.” No. 18-0044 (Jan. 31, 2020).

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