Waddle v. Elrod

Waddle transferred a half-interest in property to her niece Elrod by quitclaim deed; a buyer later sued both, alleging Elrod had procured the deed through undue influence, and Waddle cross-claimed against Elrod on the same theory. The parties settled, agreeing Elrod would transfer her interest back to Waddle, and their attorneys confirmed the settlement by email, but Elrod later reneged, prompting Waddle to seek judicial enforcement.

Whether the statute of frauds applies to a transfer of an interest in real property, and whether a settlement agreement conveying that interest may be documented through a combination of attorney emails and pleadings.