Custis v. Valley National Bank of Phoenix
In Custis v. Valley National Bank of Phoenix, 92 Ariz. 202, 375 P.2d 558 (1962), the plaintiff sought damages for the defendant's breach of an agreement to sell some of the defendant's company stock to the plaintiff and also to lease his premises to plaintiff. Id. at 203, 375 P.2d at 559.
A letter signed by both parties seeking a parent company's approval of the transaction was incomplete and did not satisfy the statute of frauds. Id. at 206, 375 P.2d at 561.
In the alternative, the plaintiff alleged that he had changed his position by continuing to work, by visiting the parent company to try to secure approval, and by obtaining a loan to perform his obligations under the agreement. Id. at 207, 375 P.2d at 561-62.
Nonetheless, the Arizona Supreme Court observed that to establish equitable estoppel, more is required than mere loss of the benefit of the alleged agreement. Id.