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Contracts Keyed to Templin
Crabtree v. Elizabeth Arden Sales Corp.
Citation:305 N.Y. 48 (1953)
While interviewing for a position with Elizabeth Arden Sales Corp. (defendant), Nate Crabtree (plaintiff) requested a three-year employment contract at $25,000 a year. Elizabeth Arden, the defendant’s president, instead offered a two-year contract with a salary of $20,000 for the first six months, $25,000 for the next six months, and $30,000 for the second year, plus travel expenses. The plaintiff responded that the offer was “interesting,” and Miss Arden had her personal secretary draft a memorandum of the agreement on a telephone order blank. The memo was titled “Employment Agreement with Nate Crabtree,” listed the salary increases, and stated “2 years to make good” at the bottom. The memo was not signed. The plaintiff then accepted the position with the defendant. Although the plaintiff received a salary increase after the first six months per a payroll change card signed by his general manager, he did not receive a salary increase at the next six month mark. The comptroller prepared and signed a payroll change card to increase the plaintiff’s salary “per contractual arrangements with Miss Arden,” but Miss Arden ultimately refused to approve the increase. The plaintiff left the defendant’s employment and sued the defendant for breach of contract.
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