Washington Law Review


Eldon C. Parr


Action on a contract whereby P agreed to sell and D to buy 4200 day-old poults. Such a contract is unenforceable unless a memorandum signed by D is sufficient to satisfy the requirements of the statute of frauds. RCW 63.04.050 (1) [RRS § 5836-4(1)]. P relied on a printed contract form, filled in by P but unsigned by either party, and a postal card signed by D on which D wrote, "Dear Mr. Grant: I have decided to not raise any turkeys this year so will you please cancel my order? . . ." P contended that the word "order" incorporated by reference the terms of the form filled in by P. Judgment for P. On appeal, Held: Reversed. Grant v. Anvil, 39 Wn. 2d 722, 238 P. 2d 393 (1951).

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