Kolkman v. Roth
Supreme Court of Iowa
656 N.W.2d 148 (Iowa 2003)
Corrine Roth (defendant) inherited farmland in 1995 and, in 1996, orally agreed to let Dean Kolkman (plaintiff) live on the farm rent-free if he would farm the land and raise cattle. Kolkman and his wife moved onto the farm that June. In 1999, Roth demanded $550 monthly rent; Kolkman refused and sued for breach of the 1996 oral agreement. Roth sought summary judgment, arguing the statute of frauds barred enforcement of an oral lease of a year or more. The district court denied summary judgment, and at trial the court found Kolkman had established promissory estoppel; the jury awarded him $154,429.00.
Whether the doctrine of promissory estoppel can remove an oral agreement from the scope of the statute of frauds.