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Christie v. Estate of Christie

Supreme Court of Minnesota

May 16, 2018

James F. Christie, Respondent,
v.
Estate of Dilman Christie, et al., Appellants.

          Court of Appeals Office of Appellate Courts

          Ryan B. Magnus, Blair Magnus PLLC, Mankato, Minnesota; and Adam J. Houck, Adams, Rizzi & Sween, P.A., Austin, Minnesota, for respondent.

          Ken D. Schueler, Jennifer M. Peterson, Dunlap & Seeger, P.A., Rochester, Minnesota, for appellants.

         SYLLABUS

         The district court erred by failing to instruct the jury to apply the clear-and-convincing-evidence standard when determining the existence of an oral contract for the sale of land between a son and the estates of his parents, where the son requested damages as a remedy.

         Reversed and remanded.

          OPINION

          ANDERSON, Justice.

         This dispute is on its second appeal, following two jury trials, and requires us to decide whether the preponderance-of-the-evidence standard or the clear-and-convincing-evidence standard applies when determining the existence of an oral contract for the conveyance of farmland when only money damages are sought for the claimed breach of that contract. James Christie claims that his parents, Dilman and Dorothy Christie (now represented by their estates), were obligated under an oral contract for the sale of land to convey farm property to him. At the second trial in this case, the jury found by a preponderance of the evidence that an oral contract existed between James and his parents and awarded James damages for the breach of that contract. The district court concluded that James had detrimentally relied on the alleged oral contract and based on that determination, concluded that the statute of frauds, which would have otherwise barred enforcement of the contract, did not apply. The estates of Dilman and Dorothy ("the Estates") moved for judgment as a matter of law and a new trial, asserting primarily that the standard of proof that the jury used to decide whether the contract existed was erroneous. The district court denied the motion, the court of appeals affirmed, and we granted the Estates' petition for review. We now reverse the decision of the court of appeals and remand to the district court for a new trial.

         FACTS

         Respondent James Christie contends that he and his parents had an oral agreement concerning the sale of farmland, but appellants, the Estates, assert that there was no agreement. The alleged agreement was reached when James was experiencing significant financial difficulty. According to James, he and his parents orally agreed that (1) James would transfer ownership of his 470-acre farm to Dilman and Dorothy; (2) Dilman and Dorothy would borrow the funds, secured by a mortgage on the property, to finance the purchase of the land, with the loan proceeds going to pay off the debt of James; (3) James would make the loan payments; and (4) Dilman and Dorothy would transfer title to the property to James after the mortgage was satisfied. James eventually paid off the mortgage debt, but Dilman's estate[1] refused to convey title to the land to James.

         James sued the Estates for enforcement of the alleged oral contract. Although a warranty deed reflects the conveyance of the property from James to Dilman and Dorothy (as joint tenants) in January 2004, it is undisputed that there is no documentation of an agreement to re-convey the land to James upon his satisfaction of the mortgage and payment of other expenses. In the original complaint, James asserted both legal and equitable causes of action and requested both legal and equitable relief.

         At the end of James's case-in-chief during the first trial, the Estates moved for judgment as a matter of law and the district court granted the motion, concluding that there was insufficient evidence that the parties had entered into an oral contract. In addition, the district court concluded that the statute of frauds, which requires contracts for the sale of land to be in writing, Minn. Stat. § 513.05 (2016), prevented enforcement of the alleged contract.

         The court of appeals reversed and remanded for a new trial, concluding that there was sufficient evidence of an oral contract to submit the issue to the jury. See Christie v. Estate of Christie (Christie I), No. A14-2196, 2015 WL 5825096, at *1 (Minn.App. Oct. 5, 2015), rev. denied (Dec. 29, 2015).

         At the second trial, the claim was tried as a breach-of-contract claim with damages as the sole remedy. But the parties disagreed about the standard of proof. The district court decided that preponderance of the evidence was the appropriate standard, rejecting the ...


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