## Facts

- A landowner inherited approximately 800 acres of Iowa farmland in 1995; the tenant had been farming it under an oral 50–50 crop-share arrangement with the prior owner.
- In spring 1996, the landowner asked the tenant to continue farming and raising cattle as before; they orally agreed the tenant would continue operations and live rent-free in a farmhouse.
- The tenant and his wife moved onto the farm in June 1996 and, from 1996 to 1999, operated the farm and performed substantial upkeep and improvements (including repairing buildings and removing debris and manure) beyond typical tenant duties.
- In 1999, the landowner sought to impose monthly rent for the farmhouse and proposed a written lease terminating in 2000; the tenant refused and the landowner attempted to terminate the tenancy.
- The tenant sued, alleging the landowner had promised he could farm on a 50–50 basis and live rent-free until he retired or could no longer work, and that he materially relied on that promise.

## Issues

1. Whether promissory estoppel may permit enforcement of an oral farm lease exceeding one year despite the statute of frauds.
2. Whether the evidence supported submitting promissory estoppel to the jury and sustaining the verdict.
3. Whether the $154,429 damages award was supported by the record.

## Decision

- The Iowa Supreme Court affirmed the judgment for the tenant and affirmed the intermediate appellate decision.
- The court held promissory estoppel can operate as an exception to the statute of frauds in an action for breach of an oral lease exceeding one year.
- The court concluded the jury could find a clear and definite promise, reasonable and detrimental reliance, and that enforcement was necessary to prevent injustice.
- The court upheld the jury’s $154,429 award as supported by evidence and not speculative.

## Legal Principles

- Iowa promissory estoppel requires: (1) a clear and definite promise; (2) the promisor should reasonably expect the promise to induce action or forbearance; (3) the promise induces such action or forbearance; and (4) enforcement is necessary to avoid injustice.
- An oral lease within the statute of frauds may still be enforced through promissory estoppel when the elements are proven and nonenforcement would be unjust.
- Reliance may be shown by significant changes in position, including relocation, sustained performance, and substantial improvements benefiting the promisor beyond ordinary obligations.

## Conclusion

The court enforced the landowner’s long-term oral farming-and-housing promise under promissory estoppel, notwithstanding the statute of frauds, because the tenant’s substantial, reasonable reliance made nonenforcement unjust, and it affirmed the jury’s damages award.


Kolkman v. Roth, 656 N.W.2d 148 (Iowa 2003)