A contract for the transfer of a real property interest can satisfy the Statute of Frauds if any two of the following have occurred: payment, possession, or improvements of the property.

• A. one, reliance
• B. one, possession
• C. two, reliance
• D. two, possession

Answer: (D)

Under the Statute of Frauds, contracts for real property must be in writing, but there’s an exception called part performance: if two of the listed acts have occurred, the contract can be enforceable even without a writing. The acts are payment, possession, and improvements. This question tests that rule by asking which scenario satisfies the requirement.

Two acts must have occurred and one of them must be possession, so the situation that meets the test is when there have been two acts in total and possession is among them (for example, possession plus payment or possession plus improvements). The other options don’t fit because they either involve only a single act, or include an element (reliance) that isn’t one of the acts counted under part performance.