Summary of Monarco v. Lo Greco
Supreme Court of California, 1950.
Facts: D reasonably relied to his detriment in his family’s promise that if he worked in the family venture, he would get the land. D passed other opportunities and worked with family for little pay. With D’s hard work, family land worth increased to $100,000. Father changed his mind and gave land to other grandson (P). P argues that D’s claim to land because of promissory estoppel was invalid because there was no writing and since this is a property it required written agreement to meet SOF.
Issue: Was the oral agreement between father and D enforceable?
Rationale: According to the court: “The doctrine of estoppel to assert the statute of frauds has been consistently applied by the courts of this state to prevent fraud that would result from refusal to enforce oral contracts in certain circumstances." The events in the current case fall under the category of cases where SOF etoppel doctrine has been applied. D relied on father’s oral promise and passed other opportunities and worked diligently to improve the value of family venture. Furthermore, the father was unjustly enriched by D’s labor. Therefore, promissory estoppel and restitution both trump the SOF requirements in this case.