New York Court of Appeals

James Against M. and S. Patten.

December 5, 18516 N.Y. 9

Summary

The Court reversed the lower court's judgment, holding that the memorandum of the corn sale was not a valid note under the revised Statute of Frauds because it was not subscribed with a manual signature at the end, and therefore the contract was unenforceable. The decision was based on the legislative intent behind the word "subscribed" and prior authority, and the case was remanded for a new trial.