Byrne v. Laura 52 Cal.App.4th 1054, 60 Cal.Rptr.2d 908 (1997) Byrne lived with a man named Lavezzo, but they never married. Lavezzo died. They never married because Byrne had handicapped children who would lose their insurance benefits if she remarried. Byrne and Lavezzo had lived together for 5 years and their possessions and bank accounts were co-mingled. Lavezzo had an obsolete will that gave everything to his (predeceased) parents. or if they were not alive to someone Suy. Lavezzo died. Suy contacted Byrne and told her to move out of the house or pay rent. Byrne filed a creditor's claim against Lavezzo's estate claiming that she was the sole and exclusive owner of all the property. The claim was denied. Byrne sued the estate (represented by Laura) for several things: Byrne argued that there was an oral agreement between her and Lavezzo to provide for her needs for the rest of her life. Byrne also argued that the property was held in a joint tenancy, even if that was never in writing. Byrne argued that she alternately deserved money for services provided (aka quantum meruit) to Lavezzo while he was alive. Laura countersued for unpaid rent that Byrne racked up living in Lavezzo's house after he died. The Trial Court found for Laura in summary judgment, dismissed Byrne's claims, and charged her $2k in unpaid rent. Byrne appealed. The Trial Court did allow Byrne to assert her quantum meruit claim, but everthing else was thrown out. The Appellate Court reversed and remanded for trial. The Appellate Court found that Byrne's claims rested on a finding of fact about Lavezzo's promises, and could not be adjudicated via summary judgment. Since Byrne relied on Lavezzo's promises, there was an equitable estoppel issue. Byrne had changed her life, by quitting her job and moving in with Lavezzo. That counts as reliance on a promise, which makes her eligible for getting their contract enforced due to equitable estoppel. Remember that from Contract Law? Was the reliance enough to justify equitable estoppel? That was for a jury to decide. In general, wills fall under the Statute of Frauds and must be in writing, but there were factual issues of what Lavezzo was providing for in a will, what was an inter vivos gift, and what was a contract to provide for Byrne's needs, etc. So the fact that there was no written will did not preclude Byrne's claims. Equity can get around the Statute of Frauds. This case was pretty shocking in that the Court used equitable estoppel in order to invalidate an otherwise valid will! This ruling is not followed in all jurisdictions.