Boone v. Coe, 153 Ky. 233, 154 S.W. 900 (Ky. 1913)
Boone v. Coe is a foundational Statute of Frauds case taught in Contracts courses to illustrate the limits of damages when an oral agreement is unenforceable.
May a plaintiff recover reliance damages for expenses and losses incurred in preparing to perform an oral agreement that falls within the Statute of Frauds, where the defendant has received no benefit from the plaintiff's actions?
Agreements within the Statute of Frauds, including leases or interests in land for a term not to be performed within one year and agreements not performable within one year from their making, are unenforceable absent a signed writing. When such an oral agreement is unenforceable, the plaintiff may not recover expectation or reliance damages that would indirectly enforce the contract. Recovery, if any, is limited to restitution for the reasonable value of benefits conferred on and accepted by the defendant to prevent unjust enrichment; where the defendant received no benefit, no recovery lies.
No. Because the oral agreement fell within the Statute of Frauds and the defendant received no benefit from the plaintiffs' preparations, plaintiffs could not recover expectation or reliance damages. With no benefit conferred on the defendant, restitution was unavailable, and the action failed.
Boone v. Coe is a cornerstone case showing that when the Statute of Frauds renders an oral contract unenforceable, plaintiffs cannot use reliance damages as an end-run around the statute. It sharpens the doctrinal boundaries between expectation, reliance, and restitution, and it is frequently contrasted with cases permitting quantum meruit when the defendant is unjustly enriched. For students, Boone highlights the need for a writing for agreements within the Statute of Frauds and provides a cautionary example that preparatory expenditures are not recoverable absent a recognized exception or an actual benefit conferred on the defendant.