Clay v. Landreth
Court of Appeals of Virginia
45 S.E.2d 875 (1948)
Landreth (defendant) contracted to buy commercial real estate from Clay (plaintiff), with both parties knowing Landreth intended to build a refrigerated storage facility there. After the contract was signed, the city rezoned the property for purely residential use, and Landreth refused to proceed with the purchase. Clay sued for specific performance, arguing the doctrine of equitable conversion required Landreth to take the property regardless of the zoning change; the trial court denied specific performance, and Clay appealed.
Whether, under Virginia law, a contract for the purchase of real property will be specifically enforced when circumstances arising after the execution of the purchase agreement would make specific performance inequitable.