Statute of Frauds Bars Enforcement of Real Estate Contract Where Legal Description Deferred to Future Survey

In Village Crossing v. West Creek Investments, the Texas Business Court granted summary judgment for the seller, holding that a purchase agreement for approximately 11.56 acres was unenforceable under the statute of frauds because it failed to adequately describe the property boundaries and impermissibly deferred the legal description to a future survey commissioned by the buyer. The court rejected the buyer's attempt to enforce the contract for only the frontage tract at the blended price, finding that the agreement contemplated a single integrated transaction combining interior and frontage acreage.