Crabtree v. Elizabeth Arden

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Crabtree v. Elizabeth Arden
Court New York Court of Appeals
Citation 305 N.Y. 48
110 N.E.2d 551
Date decided January 21, 1953


In 1947, Nate Crabtree entered negotiations with Elizabeth Arden to work as a sales manager. Crabtree asked for a 3-year contract at $25,000/year.

Arden replied with a 2-year contract for Crabtree. Crabtree's general manager listed his initial salary on his payroll card at $20,000/year. For the 2nd year, Arden declined to approve Crabtree's salary raise that the comptroller (finance officer) was okay with.

Procedural History

Crabtree resigned & sued Arden for breach of contract for refusing to approve the salary increase for the 2nd year.

Crabtree won in the New York trial court ("Supreme Court" of New York). Crabtree was awarded $14,000 in damages.

The Appellate Division affirmed in favor of Crabtree.


Can multiple documents be read together to create a memorandum of a contract adequate to satisfy the statute of frauds?


Yes. Multiple documents read together can constitute a signed writing sufficient to satisfy the statute of frauds.




Judge Fuld: An agreement doesn't have be in 1 (single) document. Several documents may be connected if they address the same topic & are supported by supplemental parol evidence (oral testimony).

In this case, we have 3 documents referring to the same employment contract for Crabtree.