Quan Shew Yung v. Woods

In Quan Shew Yung v. Woods (1963) 218 Cal. App. 2d 506, a mother and son were joint tenants on certain commercial property. The mother kept a low profile while the son negotiated a sale of the property with the plaintiff. In reliance on the purchase contract, the plaintiff entered the property and made improvements. ( Id. at pp. 508-509.) In a suit for specific performance, the defendants claimed the contract was unenforceable, since the mother did not sign a writing making the son her agent. The court disagreed, holding that the mother's acquiescence to the transaction coupled with the plaintiff's detrimental reliance thereon constituted an estoppel, which took the case out of the statute of frauds. ( Id. at pp. 511-513.)