Waddle v. Elrod
Supreme Court of Tennessee
367 S.W.3d 217 (2012)
The statute of frauds applies to the transfer of an interest in real property and requires that such contracts be in writing to be enforceable.
Relevant Facts
In 2001, Earline Waddle transferred a half interest in real property to her niece, Lorene Elrod, via quitclaim deed. In 2007, Waddle contracted to sell part of this property to Regent Investments 1, LLC (Regent), who then sued Waddle and Elrod for specific performance, alleging undue influence by Elrod in obtaining the deed. Waddle cross-claimed against Elrod with the same allegation. Regent settled with both parties, and Waddle and Elrod agreed to a settlement where Elrod would transfer her interest back to Waddle. The attorneys confirmed this agreement through emails, but Elrod later reneged. Waddle sought judicial enforcement of the settlement, which the trial court granted, and the court of appeals affirmed.
Issue
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Holding & Reasoning
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Concurrence
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Dissent
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Last updated:
December 8, 2023
Judicial Opinion
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Procedural History
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Citations
367 S.W.3d 217 (2012)