Vogt v. Madden

Vogt (plaintiff) had a two-year oral sharecrop agreement with Madden (defendant) to farm land and split net profits. After the second year, Vogt claimed a third-year agreement had formed through Madden's silence in response to his renewal proposal; Madden never farmed the land in year three. A jury found for Vogt, and Madden appealed.

Whether an agreement is created by one party's silence, given that agreements existed between the parties for two preceding years.