When Does an Email Satisfy the Statute of Frauds? Part 2 — Real Property

Our post of October 3, 2007, discussed New York General Obligations Law § 5-701 and the question of when a an email — with the sender’s name typed at the end — may suffice to satisfy the statute of frauds in the context of a personal services contract. In contrast, Vista Dev. Corp. v. VFP Realty LLC, 17 Misc. 3d 914 (Sup. Ct. Queens County Oct. 7, 2007), concerned a contract for the sale of real property. Held, a typewritten signature at the end of an email is statutorily insufficient to create a binding agreement to sell real property. “[T]he intent of the legislature was to amend the method for establishing agreements required to be in writing other than those involving contracts and conveyances concerning real property, which are purposely dealt with in a separate subdivision of Title 5.”

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