A landowner orally agrees to sell her farm to a buyer. The buyer pays part of the price, takes possession, and builds a barn on the land. The landowner then refuses to convey, citing the Statute of Frauds. What is the buyer's best argument?
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A
The part performance doctrine takes the oral land contract out of the Statute of Frauds
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B
Oral land contracts are always enforceable if witnessed
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C
The Statute of Frauds applies only to goods
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D
Payment alone always satisfies the Statute of Frauds for land