Crabtree v. Elizabeth Arden Sales Corp.
Court of Appeals of New York
110 N.E.2d 551 (1953)
Crabtree (plaintiff) negotiated a two-year, escalating-salary employment agreement with Elizabeth Arden Sales Corp. (defendant), memorialized in an unsigned memorandum drafted by the company president's secretary noting salary terms and "2 years to make good," followed by two signed "payroll change cards" from company staff detailing his salary but not the contract's duration. When Crabtree's second scheduled raise was denied after six months, he quit and sued for breach of the two-year agreement; Arden argued no such contract existed or, if it did, it was barred by the statute of frauds since no single signed document stated all material terms including duration.
Whether multiple documents taken together may constitute a signed writing sufficient to fulfill the statute of frauds if all documents refer to the same subject matter or transaction and at least one is signed by the party to be charged with the contractual obligations.