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Crabtree v. Elizabeth Arden Sales Corp.

Court of Appeals of New York
305 N.Y. 48 (1953)



In September 1947, Nate Crabtree (plaintiff) entered into negotiations with Elizabeth Arden Sales Corp. (Arden) (defendant) for employment as a sales manager. Elizabeth Arden, president of Arden, agreed to offer Crabtree a two year contract with a salary of $20,000 for the first six months, $25,000 for the next six months, and $30,000 for the second year. Crabtree replied that the offer was “interesting.” Ms. Arden directed her personal secretary to draft a memorandum of the agreement as discussed with Crabtree. The agreement stated the salary, party names, and position to be offered to Crabtree. It did not expressly state the duration of the contract, but included the notation “2 years to make good.” The memorandum was not signed. Crabtree accepted the position via telephone. When Crabtree reported to work, Mr. Johns, executive vice president of Arden, drafted and initialed a “payroll change card” outlining Crabtree’s agreed-upon salary agreement. After six months of employment, Crabtree’s salary was increased to $25,000. After the next six months, however, Crabtree did not receive an additional increase. He contacted Mr. Carstens, Arden’s comptroller, who drafted and signed an additional payroll change card detailing Crabtree’s salary arrangement. Ms. Arden refused to approve the increase, and Crabtree terminated his employment and brought suit against Arden in New York state court for breach of contract. The trial court held for Crabtree and awarded $14,000 in damages, and the appellate court affirmed. Arden appealed, arguing that the employment contract for two years did not exist, and that even if it did, it was barred by the statute of frauds.

Rule of Law


Holding and Reasoning (Fuld, J.)

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