James F. Christie, Respondent,
Estate of Dilman Christie, et al., Appellants.
of Appeals Office of Appellate Courts
B. Magnus, Blair Magnus PLLC, Mankato, Minnesota; and Adam J.
Houck, Adams, Rizzi & Sween, P.A., Austin, Minnesota, for
Schueler, Jennifer M. Peterson, Dunlap & Seeger, P.A.,
Rochester, Minnesota, for appellants.
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.
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.
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 refused to convey title to the land to
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.
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.
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).
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 ...