Law School Case Briefs

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Ries Biologicals, Inc. v. The Bank of Santa Fe

Court of Appeals for the Tenth Circuit (1986) | 780 F.2d 888; 20 Fed. R. Serv. 237; 1986 U.S. App. LEXIS 21677

4 min read

TL;DR: A bank orally guaranteed payment for supplies shipped to its struggling debtor. The court held the bank liable, finding the guarantee enforceable despite the Statute of Frauds and an ultra vires defense.

Legal Significance: This case illustrates the application of the "main purpose" and "full performance" exceptions to the Statute of Frauds for oral guarantees, and limits the ultra vires defense when a bank acts to protect its own financial interests.

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