In Exxon v. Breezevale Ltd., 82 S.W.3d 429, 441 (Tex. App.--Dallas 2002, no pet.) the facts pertain to an oral contract involving an interest in an oil and gas lease. 82 S.W.3d at 434-35.
The court of appeals concluded that the statute of frauds applied to the oral agreement involving an oil and gas lease. Id. at 437.
The court of appeals also rejected two exceptions to the statute of frauds--promissory estoppel and partial performance--that the jury concluded were applicable. Id. at 439-41.
In analyzing the partial performance exception to the statute of frauds, the court of appeals noted that "the doctrine of partial performance also requires that the party acting in reliance on the agreement suffer a substantial detriment for which there is no adequate remedy. . . . If Breezevale were successful in removing the oral agreement from the statute of frauds because of partial performance, Breezevale would be entitled to only reliance damages." Id. at 441.