Decedent orally agreed that if plaintiff would render services as housekeeper, practical muse and general business associate, he would devise and bequeath one-half of his estate to her. Decedent died without having made a will, and plaintiff sought specific performance of the agreement. Held, performance of these services did not take the oral contract out of the operation of the statute of frauds because the services were capable of measurement in money, and recovery on a quantum meriut basis was adequate. Snyder v. Warde, 151 Ohio St. 426, 86 N.E. (2d) 489 (1949).
C. J. Rice,
SPECIFIC PERFORMANCE-ORAL PROMISE TO DEVISE IN CONSIDERATION OF PERSONAL SERVICES,
Mich. L. Rev.
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