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Crabtree v. Elizabeth Arden Sales Corp - Case Brief Summary (New York)

In Crabtree v Elizabeth Arden Sales Corp., 305 NY 48 (1953), which concerned an employment contract, the Court of Appeals held that in the context of the statute of frauds, a series of signed and unsigned writings may be read together, providing they clearly refer to the same subject matter or transaction, so as to form a contract (305 NY at 55).

As Judge Fuld explained, the statute of frauds allows a contract to be "'pieced together out of separate writings, connected with one another either expressly or by the internal evidence of subject matter and occasion.'" (Id. at 54.)

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