Bull Riders v. AutoZone

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Bull Riders v. AutoZone
Court Colorado Supreme Court
Citation 113 P.3d 757
Date decided June 13, 2005
Appealed from 10th Circuit

Facts

  • The Professional Bull Riders, Inc. = PBR = "Bull Riders" = a major professional bull-riding organization
  • AutoZone, Inc. = "AutoZone" = sponsor of events for Bull Riders = a major American auto parts retailer
  • Bull Riders presented a contract where AutoZone would sponsor Bull Riders in 2001 & 2002
    • AutoZone could terminate its sponsorship by giving a notice before August 15th 2001
    • AutoZone never signed this contract
  • In January 2002, AutoZone informed Bull Riders that the sponsorship would not be happening in 2002.

Procedural History

  • Bull Riders sued AutoZone claiming a breach of the oral contract.
  • The district court granted summary judgment for AutoZone.

Issues

Is an oral contract void under the statute of frauds when it offers alternate methods of performance, 1 of which can be performed within 1 year?

Arguments

Bull Riders contended that AutoZone acted as if the un-signed contract had taken effect.

Holding

No. An oral contract isn't void under the statute of frauds when it offers alternate methods of performance, 1 of which can be performed within 1 year.

Judgment

Reversed

Reasons

  • AutoZone didn't give notice of its intent to terminate the contract in August 2001
  • AutoZone acted as if there was a contract until January 2002.

Rule

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