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A seller orally agreed to sell a parcel of land to a buyer. The buyer paid half the purchase price, moved onto the land with the seller's permission, and built a driveway and utility connections. The seller then refused to close and asserted the statute of frauds.
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The buyer may seek enforcement if acts such as possession, payment, and substantial improvements clearly point to the alleged land contract. The oral land contract is automatically enforceable because all oral contracts are valid. Part performance is irrelevant to land contracts. The oral land contract can never be enforced because land contracts always require a notarized deed before any remedy is available.

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