Haase v. Glazner

This case requires us to decide whether a party can maintain a claim based on either fraud or fraudulent inducement when that claim is premised on a contract that the Statute of Frauds makes unenforceable. We hold that a plaintiff cannot assert a fraudulent inducement claim in the absence of a contract. We further hold that under the facts of this case, to the extent that Glazner seeks to recover the benefit-of-the-bargain damages related to a contract that is unenforceable under the Statute of Frauds, the Statute bars the fraud claim, but that Glazner’s fraud claim for out-of-pocket damages,…