Wills v. Young
In Wills v. Young, 255 F.2d 65 (3d Cir. 1958) the court denied specific performance because the terms of the contract were not definite enough and it would not be possible for a competent surveyor to find the land in question from the agreement or from the references made to it.
In that case the description at issue involved an easement and stated '"The seller hereby reserves to himself and his successors an easement of thirty feet on the lot II2A as a road."' Id. at 67.
Finding this description too ambiguous, the Court declared:
"...equity can enforce a contract only where it is reasonably certain of the subject matter of its enforcement. This general principle applies to the specific enforcement of agreements relating to the purchase of land. As a condition of the enforcement of such an agreement, the land must be described in the agreement with reasonable particularity."
The court went on to state:
"...a thing will be considered certain which can be made certain. Many cases have expressed the controlling principles involved here by holding that a description is adequate if it would enable a competent surveyor to find and identify the land with the aid only of the description itself and of proper extrinsic facts referred to in the agreement." Id.