Alameda Belt Line v. City of Alameda

In Alameda Belt Line v. City of Alameda (2003) 113 Cal.App.4th 15, the court decided that language in a 1924 option to repurchase railroad property complied with the statute of frauds despite uncertain language describing the applicable real property. Although the option agreement vaguely referred to the real property as the "'belt line railroad including all extensions thereof'" (id. at p. 19), the court held that the language was sufficiently certain to satisfy the statute of frauds because the parties could consult extrinsic evidence, in the form of legal documentation of the original railroad property and of all of the subsequently acquired property for the extensions, to make the description of the real property more certain (id. at pp. 22-23). The Court explained that the contractual language was a "sufficient 'means or key' by which extrinsic or parol evidence could be used to define the property which is the subject of the option." (Alameda, at p. 22.)