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Can an employee avoid the statute of frauds based solely upon his detrimental reliance on an employer's oral promise of continued employment? Jurisdictions have divided on this question. See Annotation, 'Action By Employee In Reliance On Employment Contract Which Violates Statute Of Frauds As Rendering Contract Enforceable,' 54 A.L.R.3d 715 at §§ 11-13 (1974); 3 S. Williston, A Treatise on the Law of Contracts § 533A (3d ed. 1960); 2 A. Corbin, Corbin on Contracts § 459 (1950 & Supp. 1990). 

Some have permitted avoidance based on theories of promissory estoppel, McIntosh v. Murphy, 469 P.2d 177, 181 (Haw. 1970), equitable estoppel, Pursell v. Wolverine-Pentronix, Inc., 205 N.W.2d 504, 506 (Mich. Ct. App. 1973), or part performance, Stevens v. Good Samaritan Hosp. and Medical Center, 504 P.2d 749, 752 (Or. 1972). Others have rejected such an avoidance as contrary to the policy of the statute, Tannenbaum v. Biscayne Osteopathic Hosp., 173 So.2d 492, 495 (Fla. 1965), or as unsupported by sufficient evidence to verify the oral promise, Hudson v. Venture Industries, Inc., 252 S.E.2d 606, 608 (Ga. 1979). Some contend they can avoid the statute of frauds under the promissory estoppel theory ...

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