Unsigned Emails and Text Messages Do Not Constitute a Fully Executed Contract For the Sale of Real Property as Required by the Statute of Frauds

Unsigned Emails and Text Messages Do Not Constitute a Fully Executed Contract For the Sale of Real Property as Required by the Statute of Frauds.

In the case of Walsh v. Abate, 47 Fla. L. Weekly D702 (Fla. 4th DCA 2022) , the Fourth District Court noted in a case for a contract for the sale of real property, the statute of frauds requires that, “the contract must be a writing signed by the party against whom enforcement is sought,” and “the writing must contain all of the essential terms of the sale and these terms may not be explained by resort to parol evidence.”  (Citing Fox v. Sails at Laguna Club Dev. Corp., 403 So.2d 456 (Fla. 3d DCA 1981).