Baylor University v. Sonnichsen

In Baylor University v. Sonnichsen, 221 S.W.3d 632 (Tex. 2007), Tom Sonnichsen was hired to be the university's women's volleyball coach in 1989. Id. At a meeting in May of 1995, Baylor administrators informed their coaching staff that they planned to offer written two-year contracts to all of their head coaches, and written one-year contracts to their assistant coaches. Id. at 634. On December 29, 2005, Baylor advised Sonnichsen that he would not be awarded a contract for the 1996-97 school year. Id. Subsequently, Sonnichsen sued for breach of contract and fraud. The Texas Supreme Court held in Baylor that "a breach of contract claim based on an oral promise to enter a contract that is not performable in one year and is not in writing is barred by the statute of frauds." Id. at 635. Sonnichsen alleged in the alternative that Baylor "committed fraud by representing that it would issue a two-year written contract to him." 221 S.W.3d at 634. However, the Texas Supreme Court concluded that, "the statute of frauds bars a fraud claim for benefit-of-the-bargain damages when the claim arises from a contract that has been held to be unenforceable." Id. at 636.