This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The case involves an alleged oral agreement between a husband and his father-in-law, where the father-in-law purportedly promised the marital community a house and a one-half ownership interest in a family business in exchange for the husband moving to Santa Fe and working in the family business. The husband worked for 20 years under this arrangement, but the father-in-law later refused to transfer legal title to the house and business shares after the wife filed for divorce (paras 1, 4-9).
Procedural History
- District Court of Santa Fe County: Granted summary judgment in favor of the father-in-law, holding that the oral agreement was unenforceable under the statute of frauds and that the statute of limitations had expired (para 1).
Parties' Submissions
- Appellant (Husband): Argued that the oral agreement should be enforced due to his part performance, which removed the agreement from the statute of frauds. He also contended that the statute of limitations had not expired because the breach occurred only when the father-in-law repudiated the agreement after the divorce filing (paras 2, 10, 29-32).
- Appellee (Father-in-law): Asserted that the oral agreement was barred by the statute of frauds and that the statute of limitations had expired long before the lawsuit was filed. He also argued that the husband’s performance was not "unequivocally referable" to the alleged agreement (paras 2, 10, 19, 29).
Legal Issues
- Was the alleged oral agreement enforceable despite the statute of frauds due to the husband’s part performance?
- Did the statute of limitations bar the husband’s claims?
Disposition
- The Court of Appeals reversed the district court’s summary judgment and remanded the case for further proceedings (paras 34-35).
Reasons
Per Flores J. (Hartz and Pickard JJ. concurring):
The Court held that the husband raised genuine issues of material fact regarding both the statute of frauds and the statute of limitations, making summary judgment inappropriate.
Statute of Frauds:
The Court found that the husband’s part performance, including moving to Santa Fe, working for 20 years at below-market wages, and making substantial improvements to the house, raised factual issues about whether the agreement existed and whether it would be inequitable to deny enforcement. The Court emphasized that the performance need not exclude all other explanations but must be evidential of the agreement (paras 10-28).
Statute of Limitations:
The Court determined that the statute of limitations began to run only when the father-in-law repudiated the agreement after the divorce filing. Until then, the father-in-law’s conduct, such as allowing the husband to live in the house and treating him as a co-owner of the business, did not indicate a breach (paras 29-33).
The Court concluded that the evidence, when viewed in the light most favorable to the husband, warranted further proceedings to resolve the factual disputes (paras 34-35).