## Facts

- Brenda Joy Harrison and Marvin Pritchett had a long-standing personal relationship that ended in 1994.
- Harrison alleged that from about 1984 to 1994 she provided extensive household and personal services to Pritchett, his family, and employees (e.g., cleaning, cooking, shopping, catering, hair cutting, laundry, and driving).
- Harrison sued for (1) breach of an oral contract and (2) quantum meruit.
- On the oral-contract count, Harrison alleged that in 1984 Pritchett promised to establish a $250,000 trust for her benefit in exchange for her services, but he did not establish it or later liquidated it.
- On the quantum meruit count, Harrison alleged that over many years she expected to be paid, Pritchett accepted the benefits of her services, and he failed to pay their reasonable value ($250,000).

## Issues

1. Whether the alleged 1984 oral agreement was unenforceable under Florida’s statute of frauds as an agreement not to be performed within one year.
2. Whether Florida’s statute of frauds also barred Harrison’s quantum meruit claim seeking the reasonable value of services rendered and accepted.

## Decision

- The appellate court affirmed judgment on the pleadings for Pritchett on the breach-of-oral-contract count.
- The appellate court reversed judgment on the pleadings for Pritchett on the quantum meruit count.
- The case was remanded for further proceedings on the quantum meruit claim.

## Legal Principles

- Under Florida’s statute of frauds, an oral agreement that, by its terms, cannot be performed within one year is unenforceable absent a writing signed by the party to be charged.
- A claim seeking to enforce the specific terms of a long-term oral agreement falls within the statute of frauds when performance necessarily extends beyond one year.
- The statute of frauds does not bar an action in quantum meruit seeking restitution for services rendered and accepted, measured by their reasonable value, even if the alleged oral contract would be unenforceable.

## Conclusion

The court treated the alleged long-term trust-fund promise as an unenforceable oral contract under the one-year statute of frauds, but allowed Harrison to proceed on quantum meruit because restitution for benefits conferred and accepted is not barred by the statute of frauds.


Harrison v. Pritchett, 682 So. 2d 650 (Fla. Dist. Ct. App. 1st Dist. 1996)