Brantley v. Wilson
United States District Court, Western District of Arkansas
2006 WL 436121 (2006)
Brantley (plaintiff) and Wilson (defendant) exchanged emails agreeing to a $370,000 purchase price for Wilson's land, with closing costs split 50/50, though the emails never addressed a closing date, earnest money, or mineral-interest retention. After Brantley signed and sent a formal contract prepared by his attorney, Wilson emailed back that she had decided not to sell at that price after learning nearby land had sold for more, and never signed the formal contract. Brantley sued for specific performance, arguing the emails themselves formed a binding contract; Wilson moved for summary judgment, arguing no contractual intent existed, the terms were too vague, and the deal violated the statute of frauds.
Whether emails agreeing to a purchase price for a specific parcel of property, bearing the seller's typed name but omitting certain other terms, can create a valid, enforceable real estate contract under the Uniform Electronic Transmissions Act.