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4 U.S. 131

Bell v. Andrews

Supreme Court of the United States · decided 1796-03

This was an action on the case, to recover damages, for the breach of an agreement to sell and convey to the plaintiff, in fee-simple, a tract of land in Westmoreland county. offered parol evidence of the agreement, as stated in the declaration; of the payment of the price of the land; of the defendant’s subsequent acknowledgment of the sale and payment; and of the defendant’s refusal to execute a conveyance. objected to any proof of a parol agreement, for the sale of lands…

Cited by 1 later decisions — most recently February 1853

1 state decisions

2 counsel of record

Relies on Latimer & Yard v. Ridge · Clyde v. Clyde

Good law ✅— No negative treatment on recordhow we know

Decided 1796-03

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¶1Statute of frauds.

¶2Where there has been payment of the price of land, under a parol agreement for the sale of it, an action will lie to recover damages for the non-performance of such a contract. 1

¶3This was an action on the case, to recover damages, for the breach of an agreement to sell and convey to the plaintiff, in fee-simple, a tract of land in Westmoreland county.

¶4Hallowell, for the plaintiff,

¶5offered parol evidence of the agreement, as stated in the declaration; of the payment of the price of the land; of the defendant’s subsequent acknowledgment of the sale and payment; and of the defendant’s refusal to execute a conveyance.

¶6S. Levy, for the defendant,

¶7objected to any proof of a parol agreement, for the sale of lands in fee-simple, as the act for the prevention of frauds and perjuries (1 Dali. Laws, 640 ; 1 Sm. Laws, 389), required, expressly, that all such agreements, to have the full effect, must be put in writing, and be signed by the partios, or their agents. But—

¶10By the Court.

¶11— The payment of the consideration-money may, certainly, be proved by parol evidence. The agreement being then executed by one of the parties, is not affected by the act of assembly;(b) and it is settled, that the English statute against frauds and perjuries was never extended to Pennsylvania. The act of assembly does not make a parol agreement for the sale of lands, void ; though it restricts the operation of the agreement, as to the acquisition of an interest in the land, and no title in fee-simple can be derived under it. But, certainly, an action will lie to recover damages for the non-performance of such an agreement. (c)

¶12The objection to the evidence overruled.

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