Case Summary

Chambers v. Pruitt A mobile home/land sale dissolves after down payment but before a contract is signed, and the buyer sues for specific performance. Specific performance is only warranted when there is a written agreement containing critical terms.

Facts

08/2004: Pruitts sold a mobile home to Chambers. The home was supposed to be moved off the Pruitts property. 10/2004: Home still not moved, and the Pruitts sold the lot under the home. Chambers put $2400 down. Both parties prepared contracts for deed, but neither party would sign the others contract. The mobile home (and Chambers) remained on the lot. Chambers sued the Pruitts for breach of contract, and the Pruitts countersued to have Chambers evicted. The trial court awarded possession to the Pruitts and ordered Chambers to pay back rent. Chambers filed for an injunction/temporary restraining order, claiming that the oral agreement between her and the Pruitts was enforceable. Chambers was removed from the land, which the Pruitts later sold to someone else. The Pruitts won a take-nothing judgment, and Chambers appealed.

Issue

Issue 7: Can a court refuse to address whether the Pruitts committed fraud? (They made > $15K in less than a year on a $3K mobile home.) Issue 8: Does the court have discretion to rule that Chambers down payment, purchase of water rights, and 8 months of payments wasnt enough to require specific performance? Issue 9: The Statute of Frauds was designed to prevent fraud. Can the court use the Statute to allow the Pruitts to commit fraud?

Rules

Chambers v. Pruitt To prove fraud, Chambers must show: 1. a material misrepresentation; 2. that was false; 3. made by the Pruitts w/ knowledge of falsity or w/ a reckless disregard of its truth; 4. made by the Pruitts w/ the intent that Chambers act on it; 5. Chambers actual reliance on the representation; and 6. Chambers actual harm/injury. Partial performance exception to the Statute of Frauds applies when: 1. consideration is paid; 2. possession is surrendered; 3. buyer makes valuable, permanent improvements on the land OR other facts make the transaction a fraud if the oral contract isnt enforced.

Applicatio n

Chambers didnt prove any of the fraud elements. The parties failed to agree on a contractthis isnt fraud. The Pruitts retained Chambers down payment but sold the property to another personthis isnt fraud, either, b/c theres no proof that they didnt intend to sell the land to Chambers when they accepted her down payment. Contracts for land must be in writing per the Statute of Frauds. This contract wasnt, so it is unenforceable. The partial performance exception doesnt apply here, b/c Chambers didnt pay the full purchase price. The parties never agreed on a final purchase price. Also, the Pruitts didnt surrender possessionthey retained the right to evict her. Specific performance is warranted when there is a written agreement containing critical terms. Here, there is no writingno specific performance.

Conclusion

Trial court affirmedfind for the Pruitts.

Chambers v. Pruitt