Whether a written memorandum sufficed to satisfy the UCC Statute of Frauds when it failed to state the quantity term.
Held
The memorandum was insufficient because it did not state the quantity of goods sold.
Exam use
In an exam, introduce Ninth Street East, Ltd. v. Harrison with the citation only if you can remember it accurately; otherwise use the case name and court, then focus on the rule and application. A strong answer should say what Ninth Street East, Ltd. v. Harrison decided, why the facts mattered, and how the authority helps resolve the new facts. Avoid treating the case as a decorative reference. Use it to prove a doctrinal step in UCC Article 2 - Statute of Frauds, then move quickly to analysis.
Summary
Ninth Street East, Ltd. v. Harrison is included in the Sales (UCC Article 2) case database because it gives students a concrete authority for UCC Article 2 - Statute of Frauds. The reported citation is 259 A.2d 772, and the decision is associated with Supreme Court of Connecticut. In revision, treat the case as a way to connect the legal issue to a real dispute rather than as an abstract rule. The key exam move is to state the holding, identify the fact pattern that made the rule matter, and then decide whether a new problem question should apply, distinguish, or limit the authority.
Facts
The material factual signal for Ninth Street East, Ltd. v. Harrison is: A buyer claimed an oral contract for the sale of goods over $500 was enforceable based on a written memorandum. Students should read the linked source and turn that signal into a short fact table: parties, transaction or public-law setting, procedural posture, conduct in dispute, and the fact the court treated as decisive. This prevents vague case-dropping. In an answer on Sales (UCC Article 2), use the facts to explain why UCC Article 2 - Statute of Frauds was live, then compare the problem facts against the facts in the case before stating any conclusion.
Procedural History
Ninth Street East, Ltd. v. Harrison is reported as a decision of Supreme Court of Connecticut. The procedural route should be checked against the linked source before formal citation. For study notes, record whether the decision was an appeal, judicial review, trial judgment, tribunal ruling, or constitutional/application proceeding, because that posture affects how confidently the rule can be used.
Issue
Whether a written memorandum sufficed to satisfy the UCC Statute of Frauds when it failed to state the quantity term.
Held
The memorandum was insufficient because it did not state the quantity of goods sold.
Ratio Decidendi
Under UCC § 2-201, a writing must indicate that a contract for sale was made and state the quantity term to satisfy the Statute of Frauds.
Obiter Dicta
Check the linked source for concurring, dissenting, or obiter observations before quoting this case. If the case includes non-binding reasoning, use it as persuasive support rather than as the core rule.
Reasoning
For reasoning, start with the ratio: Under UCC § 2-201, a writing must indicate that a contract for sale was made and state the quantity term to satisfy the Statute of Frauds. Then read the source and separate three things: the legal test, the facts used to apply that test, and any policy or institutional reason the court gave. This structure makes Ninth Street East, Ltd. v. Harrison easier to use in essays and problem questions. In Sales (UCC Article 2), the case should be compared with related authorities on UCC Article 2 - Statute of Frauds; if the jurisdiction, statute, or procedural posture differs from the exam problem, explain that limit explicitly instead of treating the authority as automatic.
Plain-English Explanation
Plainly, Ninth Street East, Ltd. v. Harrison is a case to use when a Sales (UCC Article 2) answer needs an authority on UCC Article 2 - Statute of Frauds. Do not just list it. Explain the problem the court had to solve, the rule or holding it used, and the fact that made the result persuasive. That turns the case from a memorised name into evidence for your legal analysis.
Essay-Ready Explanation Generator
Version 1 of 4
Reference to Ninth Street East, Ltd. v. Harrison (259 A.2d 772) strengthens a Sales (UCC Article 2) answer because the case reflects the principle that Under UCC § 2-201, a writing must indicate that a contract for sale was made and state the quantity term to satisfy the Statute of Frauds. Applied to a problem question, the case should be used after identifying the issue as Whether a written memorandum sufficed to satisfy the UCC Statute of Frauds when it failed to state the quantity term. The stronger essay move is to connect the material facts to the court's holding, then explain whether the present facts support the same conclusion or justify distinguishing the authority.
Underlying Concepts
sales-ucc-article-2
Sales (UCC Article 2)
UCC Article 2 - Statute of Frauds
case authority
exam application
Key Passages
Verify exact wording in the linked source before quoting.
Significance
Ninth Street East, Ltd. v. Harrison is significant for LawConquer users because it supplies a named authority for UCC Article 2 - Statute of Frauds in Sales (UCC Article 2). The case can anchor a paragraph, support a rule statement, or provide a contrast point when another authority points the other way. Its practical value is strongest when the student links the holding to the material facts and then explains whether the present problem is analogous or distinguishable.
Related Cases
No related cases listed.
Exam Tips
In an exam, introduce Ninth Street East, Ltd. v. Harrison with the citation only if you can remember it accurately; otherwise use the case name and court, then focus on the rule and application. A strong answer should say what Ninth Street East, Ltd. v. Harrison decided, why the facts mattered, and how the authority helps resolve the new facts. Avoid treating the case as a decorative reference. Use it to prove a doctrinal step in UCC Article 2 - Statute of Frauds, then move quickly to analysis.
Revision Checklist
Name the issue before discussing facts so the marker sees the legal question immediately.
State the holding in one sentence, then use the ratio to explain why the court reached that result.
Use the citation and jurisdiction to show why this authority matters for the problem you are answering.
Pair this case with one supporting or contrasting authority if the question tests limits, policy, or exceptions.
Problem Question Use
Use Ninth Street East, Ltd. v. Harrison in a problem question by matching the factual trigger to the new scenario. If the fact pattern aligns with A buyer claimed an oral contract for the sale of goods over $500 was enforceable based on a written memorandum., apply the ratio and explain the likely result. If a crucial fact, jurisdiction, statute, or procedural posture differs, distinguish the case and use it as a boundary rather than a controlling answer.