World of Sleep, Inc. v. Seidenfeld

Seidenfeld (defendant) orally agreed to personally guarantee both a promissory note and a sublease for his company's purchases from World of Sleep (plaintiff), but when the contract documents were prepared, they included a signature line guaranteeing only the sublease, omitting the note. Seidenfeld noticed the omission but said nothing to World of Sleep. Years later, after his company defaulted on both obligations, World of Sleep sued him personally; he argued the statute of frauds barred enforcement of an unwritten personal guarantee on the note. The trial court reformed the note to include Seidenfeld's guarantee and held him personally liable on both obligations.

Whether the statute of frauds prevents a court from reforming an agreement to conform with the parties' intentions.