For a real property transaction, which combination satisfies the Statute of Frauds?

• A. Payment only
• B. Possession only
• C. Two of payment, possession, or improvements
• D. Improvements only

Answer: (C)

Real estate contracts usually must be in writing, but there’s a well-known exception called part performance. If the buyer has taken steps that clearly reference the contract, the agreement can be enforceable even without a writing. The key idea is that two distinct acts among paying the price, taking possession, and making valuable improvements demonstrate the contract’s existence. Payment alone doesn’t prove the contract, nor does possession alone or improvements alone. However, doing two of these actions together (for example, paying part of the price and taking possession, or paying and making improvements) shows enough unequivocal performance to satisfy the Statute of Frauds. That’s why the best answer is the combination of two of these actions.