Joseph Martin, Jr., Delicatessen, Inc. v. Schumacher
Court of Appeals of New York
417 N.E.2d 541 (1981)
Schumacher (defendant) leased a retail store to Joseph Martin, Jr., Delicatessen (Joseph) (plaintiff) for five years, with a renewal clause allowing Joseph to renew upon notice at a rental price to be agreed upon by the parties in the future. When Joseph tried to exercise that renewal option, Schumacher demanded $900 per month, far more than the $545.41 an appraiser hired by Joseph found to be fair market rent; Joseph sued for specific performance at either the appraised rate or a court-determined reasonable rate, while Schumacher separately sued to evict. The trial court found the renewal clause unenforceable for indefiniteness, the appellate court reversed, and the question reached the New York Court of Appeals.
Whether an enforceable contract for the transfer of real property requires an agreement to be sufficiently definite and specific regarding all material terms.