## Facts

- After his first wife died, Aubrey Milton Hall created a revocable trust and deeded his residence to himself as trustee; he remained the lifetime beneficiary, and his sons were the remainder beneficiaries at his death.
- Aubrey met Carol Anita Hall, proposed marriage, and she expressed concerns about financial security and having a place to live for the rest of her life.
- Carol alleged an oral agreement made in contemplation of marriage: if she (1) married Aubrey, (2) quit her job so they could spend most of their time together, (3) applied for Social Security at age 62, and (4) gave him $10,000 for the marriage, then she could live in his home for the rest of her life.
- Carol quit her job, moved in, applied for early Social Security, and provided Aubrey at least $10,000 (and additional funds).
- The couple met with Aubrey’s estate-planning attorney to implement the arrangement; the attorney prepared a trust amendment providing Carol a life estate, but Aubrey died before signing.
- After Aubrey’s death, Carol sued David Allen Hall (Aubrey’s son, executor, and trustee) for specific performance to establish a life estate in the residence; the trial court granted the life estate.

## Issues

1. Whether an oral premarital agreement granting a future spouse a life estate in real property is unenforceable for lack of a writing under the Uniform Premarital Agreement Act and the statute of frauds.
2. Whether equity may grant specific performance (or equivalent relief) where the promisee fully performed and materially and detrimentally relied on the oral promise.

## Decision

- The Court of Appeal affirmed the judgment awarding Carol a life estate.
- The court treated the promise as a premarital agreement within the UPAA’s scope and recognized that such agreements generally require a writing.
- The court nevertheless enforced the promise in equity because Carol fully performed and irreversibly changed her position in reliance on Aubrey’s promise.
- The life-estate decree was upheld as a proportionate remedy implementing the parties’ intended arrangement while preserving the sons’ remainder interests subject to Carol’s life tenancy.

## Legal Principles

- An oral agreement affecting an interest in land may be enforceable in equity notwithstanding writing requirements when the promisee’s full performance and detrimental reliance would make nonenforcement fraudulent or unjust.
- The UPAA’s writing requirement does not, absent clear legislative direction, eliminate traditional equitable doctrines (e.g., part performance/estoppel-type principles) that prevent injustice from reliance on an oral premarital promise.
- Specific performance may be ordered where the remedy is feasible and tailored to the promised interest (here, a life estate), rather than expanding the promisee’s rights beyond the bargain.

## Conclusion

The court affirmed specific performance of an oral premarital promise granting a life estate because the spouse fully performed and detrimentally relied, and the UPAA and statute of frauds did not bar equitable relief designed to prevent injustice.


Hall v. Hall, 222 Cal. App. 3d 578, 271 Cal. Rptr. 713 (Ct. App. 1990)