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Florida Statute 672.201 | Lawyer Caselaw & Research
F.S. 672.201 Case Law from Google Scholar
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The 2023 Florida Statutes (including Special Session C)

Title XXXIX
COMMERCIAL RELATIONS
Chapter 672
UNIFORM COMMERCIAL CODE: SALES
View Entire Chapter
F.S. 672.201
672.201 Formal requirements; statute of frauds.
(1) Except as otherwise provided in this section a contract for the sale of goods for the price of $500 or more is not enforceable by way of action or defense unless there is some writing sufficient to indicate that a contract for sale has been made between the parties and signed by the party against whom enforcement is sought or by his or her authorized agent or broker. A writing is not insufficient because it omits or incorrectly states a term agreed upon but the contract is not enforceable under this paragraph beyond the quantity of goods shown in such writing.
(2) Between merchants if within a reasonable time a writing in confirmation of the contract and sufficient against the sender is received and the party receiving it has reason to know its contents, it satisfies the requirements of subsection (1) against such party unless written notice of objection to its contents is given within 10 days after it is received.
(3) A contract which does not satisfy the requirements of subsection (1) but which is valid in other respects is enforceable:
(a) If the goods are to be specially manufactured for the buyer and are not suitable for sale to others in the ordinary course of the seller’s business and the seller, before notice of repudiation is received and under circumstances which reasonably indicate that the goods are for the buyer, has made either a substantial beginning of their manufacture or commitments for their procurement; or
(b) If the party against whom enforcement is sought admits in his or her pleading, testimony or otherwise in court that a contract for sale was made, but the contract is not enforceable under this provision beyond the quantity of goods admitted; or
(c) With respect to goods for which payment has been made and accepted or which have been received and accepted (s. 672.606).
History.s. 1, ch. 65-254; s. 557, ch. 97-102.
Note.s. 2-201, U.C.C.

F.S. 672.201 on Google Scholar

F.S. 672.201 on Casetext

Amendments to 672.201


Arrestable Offenses / Crimes under Fla. Stat. 672.201
Level: Degree
Misdemeanor/Felony: First/Second/Third

Current data shows no reason an arrest or criminal charge should have occurred directly under Florida Statute 672.201.



Annotations, Discussions, Cases:

Cases from cite.case.law:

IN RE MIAMI METALS I, INC., 603 B.R. 727 (Bankr. S.D.N.Y. 2019)

. . . . § 672.201(1) & cmt. 1 ("The only term which must appear [in the writing] is the quantity term[,] which . . . Ann. § 672.201(1) & cmt. 1. . . .

TM WIRELESS COMMUNICATION SERVICES, INC. v. ALL COMMERCE, INC., 246 So. 3d 541 (Fla. App. Ct. 2018)

. . . See § 672.201(1), Fla. . . .

BRANCH BANKING TRUST CO. OF VIRGINIA, v. M Y BEOWULF, No., 883 F. Supp. 2d 1199 (S.D. Fla. 2012)

. . . definition of “goods” contained in § 672.105, the statute of frauds provided in Article 2 of the UCC, § 672.201 . . . conduct between Sculley and Sculley Boatbuilders which would excuse the requirement of a writing under § 672.201 . . . Section 672.201, Fla. . . .

B C INVESTORS, INC. H. v. VOJAK a, 79 So. 3d 42 (Fla. Dist. Ct. App. 2011)

. . . See id. at 1289 (citing section 672.201(1), Florida Statutes, for the proposition that the statute of . . .

GE LIN, v. ECCLESTONE SIGNATURE HOMES OF PALM BEACH, LLC, a, 59 So. 3d 267 (Fla. Dist. Ct. App. 2011)

. . . what he argued in the trial court: the contract violates the statute of frauds contained in section 672.201 . . . Section 672.201 provides: (1) Except as otherwise provided in this section a contract for the sale of . . . analyzed this case based upon the application of the statute of frauds for a sale of goods, section 672.201 . . . Similar to section 672.201(1), section 725.01 requires that a contract for sale of real estate be in . . . Even if we were to decide this case under Section 672.201, we would conclude that the statement of the . . .

WHITE CONSTRUCTION COMPANY, INC. a a v. MARTIN MARIETTA MATERIALS, INC. a LLC, a, 633 F. Supp. 2d 1302 (M.D. Fla. 2009)

. . . . § 672.201. . . . Stat. § 672.201(1). . . . Stat. § 672.201). . . . Stat. §§ 672.201; 680.201. See also India America Trading Co. v. . . .

TECHNICAL PACKAGING, INC. v. HANCHETT O s, P. A., 992 So. 2d 309 (Fla. Dist. Ct. App. 2008)

. . . See generally § 672.201, Fla. Stat. (2002); 45 Fla. . . .

BOLDSTAR TECHNICAL, LLC, v. HOME DEPOT, INC., 517 F. Supp. 2d 1283 (S.D. Fla. 2007)

. . . . § 672.201(1). . . . fraud claim is essentially a contract claim repackaged as a tort action, and therefore barred by § 672.201 . . .

TOPP, INC. a v. UNIDEN AMERICA CORPORATION, a, 483 F. Supp. 2d 1187 (S.D. Fla. 2007)

. . . . § 672.201 applies to its claims and thus there is a quantity term sufficient to satisfy the Statute . . . Stat. § 725.01, the general statute, and § 672.201, which governs oral contracts for sale of goods, § . . . The undersigned finds that § 725.01, and not § 672.201, should control. . . . Stat. § 672.201, and not § 725.01, controls its indefinite oral exclusive distributorship claim. . . . Section 672.201 states that it applies to contracts for the purchase of goods worth $500 or more. . . .

H. P. B. C. INCORPORATED, a v. NOR- TECH POWERBOATS, INC. a, 946 So. 2d 1108 (Fla. Dist. Ct. App. 2006)

. . . Florida’s Uniform Commercial Code, section 672.201(1), Florida Statutes (2005), provides: Except as otherwise . . . See §§ 672.201(1), 725.01, Fla. Stat. (2005). . . . performed within one year, both the general and the Uniform Commercial Code statutes of frauds apply. §§ 672.201 . . .

BUSINESS RADIO, INC. v. RELM WIRELESS CORPORATION,, 373 F. Supp. 2d 1317 (M.D. Fla. 2005)

. . . . § 672.201(1) or Wash. Rev. . . .

AMERICAN ZURICH INSURANCE COMPANY, v. ST. GEORGE CRYSTAL, LTD., 870 So. 2d 243 (Fla. Dist. Ct. App. 2004)

. . . If so, then section 672.201, the statute of frauds provided for in article 2 of the UCC, is controlling . . . Only upon a finding that section 672.201 is not controlling need we refer to the general statute of frauds . . . Wilson, 419 So.2d 1139 (Fla. 1st DCA 1982) (excluding the applicability of section 672.201 before analyzing . . . Therefore, section 672.201, not section 725.01, is controlling on the statute of frauds issue. . . . We need not consider the enforceability of the agreement pursuant to section 672.201 because St. . . .

In CORVETTE COLLECTION OF BOSTON, INC. C. v. J., 294 B.R. 409 (Bankr. S.D. Fla. 2003)

. . . . § 672.201 states: Except as otherwise provided in this section a contract for the sale of goods for . . . Stat. § 672.201(3) sets forth three exceptions to the statute of frauds. . . . Stat. § 672.201(3)(b) that the Orally Consigned Corvettes were in the Debtor’s possession at the time . . . Stat. § 672.201(3)(c). Acceptance is defined under Fla. . . .

OFFICE PAVILION SOUTH FLORIDA, INC. v. ASAL PRODUCTS, INC. a, 849 So. 2d 367 (Fla. Dist. Ct. App. 2003)

. . . Section 672.201(1), Florida Statutes (1997), provides that a contract for the sale of goods in excess . . . contract is not enforceable under this paragraph beyond the quantity of goods shown in such writing.” § 672.201 . . . but the contract is not enforceable under this provision beyond the quantity of goods admitted.” § 672.201 . . .

CONNER, I, INC. v. WALT DISNEY COMPANY,, 827 So. 2d 318 (Fla. Dist. Ct. App. 2002)

. . . . § 672.201, Fla. Stat. (1996). . § 672.206, Fla. Stat. (1996). .§ 680.201(1), Fla. Stat. (1996). . . .

HARRIS, a v. SCHICKEDANZ BROS. RIVIERA LTD. a a, 746 So. 2d 1152 (Fla. Dist. Ct. App. 1999)

. . . authorized agent. (2) Subsection (1) of this section does not apply to contracts for the sale of goods (s.672.201 . . .

COLEMAN COMPANY, INC. v. CARGIL INTERNATIONAL CORP., 731 So. 2d 2 (Fla. Dist. Ct. App. 1998)

. . . See §§ 672.201(1), 725.01, Fla.Stat. (1995). See also Yates v. . . .

CENTRO NAUTICO REPRESENTACOES NAUTICAS, LDA. a a v. INTERNATIONAL MARINE CO- OP, LTD. a, 719 So. 2d 967 (Fla. Dist. Ct. App. 1998)

. . . UCC section 672.201 limits enforcement of oral contracts captured by the statute of frauds to only goods . . . See § 672.201(3)(c), Fla. . . . . § 672.201(1), Fla. . . .

FUTURE TECH INTERNATIONAL, INC. a v. TAE IL MEDIA, LTD. IL U. S. A., 944 F. Supp. 1538 (S.D. Fla. 1996)

. . . . § 672.201(1). . . .

ADVANCED MOBILEHOME SYSTEMS OF TAMPA, INC. Ft. Ft. v. ALUMAX FABRICATED PRODUCTS, INC., 666 So. 2d 166 (Fla. Dist. Ct. App. 1995)

. . . did not reject the terms of the invoices, and, therefore, the written terms governed under sections 672.201 . . . It based its decision on sections 672.201(2) and 672.207(2), Florida Statutes (1991). . . . The objection-on-receipt provisions in sections 672.201 and 672.207 are sometimes confused. . . . The portions of those sections relevant to this case are as follows: 672.201 Formal requirements; statute . . . Section 672.201 is not applicable here. . . .

METTLER, INC. a v. ELLEN TRACY, INC. a a, 648 So. 2d 253 (Fla. Dist. Ct. App. 1994)

. . . See §§ 672.201-.210, Fla.Stat. (1991). . . . See § 672.201(1), Fla.Stat. (1991). . . .

STEWART d b a S v. J. P. MACH AGRI- MARKETING, INC., 641 So. 2d 202 (Fla. Dist. Ct. App. 1994)

. . . .-209 and 672.201, Florida Statutes, was not raised before the hearing officer or the Department of Agriculture . . .

C. SPAZIANI, v. C. BANCROFT a, 618 So. 2d 744 (Fla. Dist. Ct. App. 1993)

. . . “signed” includes any authentication which identifies the party to be charged. 19A F.S.A. p. 121, § 672.201 . . . executed or adopted by the party with present intention to authenticate the writing. § 19A F.S.A. p. 65, 672.201 . . . contain all of the essential terms necessary to make an enforceable contract for the sale of land). . § 672.201 . . .

In ATKINS,, 139 B.R. 39 (Bankr. M.D. Fla. 1992)

. . . . § 672.201. . . .

GOLDEN NEEDLES KNITTING AND GLOVE COMPANY, INC. v. DYNAMIC MARKETING ENTERPRISES, INC., 766 F. Supp. 421 (W.D.N.C. 1991)

. . . . §§ 672.201 et seq. . . . the previous codification; that is without reference to Article 2 of the UCC (i.e., Fla.Stat.Ann. § 672.201 . . .

In HASTINGS MARINE CORPORATION, d b a, 99 B.R. 98 (Bankr. M.D. Fla. 1989)

. . . . § 672.201 governs written consignment agreements. . . .

Dr. K. KHOSHNOU, v. PAINE, WEBBER, JACKSON CURTIS, INC., 525 So. 2d 977 (Fla. Dist. Ct. App. 1988)

. . . provide that subsection (3) is “new” to Florida law, and that it is to be interpreted like section 672.201 . . . The Uniform Commercial Code Comment to 2-201(2) (672.201(2)) provides that the only effect this section . . . contract was made for sale of a stated quantity of described securities at a defined or stated price. . 672.201 . . .

J. R. SALES, INC. v. DICKS,, 521 So. 2d 366 (Fla. Dist. Ct. App. 1988)

. . . Section 672.201(3), Florida Statutes (1985); Lea Industries, Inc. v. . . .

AL BOOTH S, INC. v. BOYD- SCARP ENTERPRISES, INC., 518 So. 2d 422 (Fla. Dist. Ct. App. 1988)

. . . The statute of frauds found in the U.C.C., section 672.201, Florida Statutes (1985), is not a defense . . .

In B. DRIVER, B. DRIVER, v. FORD, a k a M. G. a k a d b a, 78 B.R. 616 (Bankr. M.D. Fla. 1987)

. . . Furthermore, FORD argues that even if he did, the Statute of Frauds provisions contained in § 672.201 . . . However, § 672.201(1), Florida Statutes, provides that “a contract for the sale of goods for the price . . . sought admits in his pleading, testimony or otherwise in Court that a contract for sale was made — ” § 672.201 . . . Accordingly, the Court is compelled to find that § 672.201(1), Florida Statutes, is applicable and that . . .

In DENMARK COMPANY, INC. L. BAKST, v. WHEELER OIL COMPANY, INC., 73 B.R. 325 (Bankr. S.D. Fla. 1987)

. . . . § 672.201) requires the production of a written consignment agreement, signed by the buyer. . . .

CENTRAL FLORIDA ANTENNA SERVICE, INCORPORATED, v. A. M. CRABTREE, Jr., 503 So. 2d 1351 (Fla. Dist. Ct. App. 1987)

. . . . §§ 672.102, 672.206, 672.201(1), Fla.Stat. (1985). . § 672.606(1), Fla.Stat. (1985). . . . .

LA ROSA, v. C. FORTIER,, 492 So. 2d 425 (Fla. Dist. Ct. App. 1986)

. . . Section 672.201(1), Florida Statutes (1983), provides in relevant part that: [A] contract for the sale . . . Further, section 672.201 is applicable to an agreement modifying a contract, as well as to the original . . .

UNITED STATES v. CONRAD,, 619 F. Supp. 1319 (M.D. Fla. 1985)

. . . upon each item; and fifth, that the contract sued upon does not satisfy the statute of frauds, Section 672.201 . . . Section 672.201(1), Florida Statutes (1983). . . .

PACKAGING CORPORATION INTERNATIONAL, v. TRAVENOL LABORATORIES, INC., 566 F. Supp. 1480 (S.D. Fla. 1983)

. . . . § 672.201(1) (1978). . . . Stat. § 672.201(3)(b) (1978). . . . Fla.Stat. § 672.201(1) (1978) states, in pertinent part, the following: Except as otherwise provided . . . Stat. § 672.201(3)(b) (1978) states that “[a] contract which does not satisfy the requirements of subsection . . .

ROZEMA, v. L. M. WILSON,, 419 So. 2d 1139 (Fla. Dist. Ct. App. 1982)

. . . motion, argued the agreement was a contract for sale and fell within the UCC Statute of Frauds, Section 672.201 . . . Section 672.201(3)(b), and was therefore enforceable. . . . for sale, falling within Article II of the UCC and therefore the Code’s Statute of Frauds, Section 672.201 . . . the issue whether the agreement is subject to the exception to the UCC Statute of Frauds, for Section 672.201 . . .

MIAMI PURVEYORS, INC. v. FORTE, BRICKELL BAY CLUB, INC. v. MIAMI PURVEYORS, INC., 407 So. 2d 330 (Fla. Dist. Ct. App. 1981)

. . . the non-jury proceedings (a) a finding that Forte’s agreement was unenforceable under either Section 672.201 . . .

CENTRAL NATIONAL BANK OF MIAMI v. MOTIF ART GALLERIES,, 49 Fla. Supp. 104 (Dade Cty. Cir. Ct. 1979)

. . . be treated as a separate contract for sale within the statute of frauds section of this chapter (s. 672.201 . . .

JIM SLIM S TOOL SUPPLY, INC. a v. METRO COMMUNITIES CORPORATION, a, 328 So. 2d 213 (Fla. Dist. Ct. App. 1976)

. . . guarantee is unenforceable under the “Statute of Frauds” provision of the Uniform Commercial Code, § 672.201 . . . Concerning, now, the Statute of Frauds provision of the Uniform Commercial Code, § 672.201, supra, we . . .

CONTRACTORS AND BUILDERS ASSOCIATION OF PINELLAS COUNTY v. CITY OF DUNEDIN,, 329 So. 2d 314 (Fla. 1976)

. . . . § 672.201 (1973), is unenforceable unless reduced to writing, with certain exceptions not pertinent . . .

ASHLAND OIL, INC. v. PICKARD MODERN FIBER GLASS, INC. L. v. PICKARD, 269 So. 2d 714 (Fla. Dist. Ct. App. 1972)

. . . memorandum signed by the party to be charged for an agreement not to be performed within one year, and § 672.201 . . . The first issue we shall discuss is whether statutes of frauds, §§ 672.201 and 725.01, may be avoided . . . However, in the case sub judice, the requirements of § 725.01 (contract for more than one year) and § 672.201 . . . To resolve the issue of whether the requirements of the statutes of frauds, §§ 672.201 and 725.01, were . . .

INTERNATIONAL DESIGN, INC. a v. RUBIN S FRANCHISES, INC. a, 247 So. 2d 778 (Fla. Dist. Ct. App. 1971)

. . . Elliott Roosevelt inasmuch as said contract falls within the provisions of Florida Statutes § 671.206, 672.201 . . .