Baker v. Lockheed Aircraft Service Co.
Harvey Baker sued Lockheed Aircraft Service Company and Bob Savage for breach of an alleged employment contract for a position in Iran. Baker claimed he accepted an oral offer, which Lockheed later withdrew, citing unsatisfactory reference checks as a condition precedent. The jury found that Lockheed's revocation was based on information from these checks. The appellate court affirmed the trial court's judgment, ruling that the written offer was tentative and subject to contingencies. The court emphasized that the statute of frauds required a complete written memorandum, and the parol evidence rule prevented converting a conditional written agreement into an unconditional oral one. Plaintiff failed to prove the satisfaction of the condition precedent.