The contract or memorandum for the sale of real estate to meet the requirements of the statute must possess the following essentials:

(a) The contract must contain a description of the land, sufficiently definite that from it the premises may be identified. It is not essential that the description describe the property by lot number or by metes and bounds as it has been held that a description referring to the property by street number, and in other cases by such general terms as "my house," "The Schoolcraft Store," and other similar terms, is sufficient.38

Description Held Sufficient Under the Statute of Frauds

38. Nowicki v. Kopelczak, 195 Mich. 678. A description of real estate in a contract described as No. 1086 Chene Street, corner of Frederick in the City of Detroit, Wayne County, Michigan, was held sufficient.

Cooper v. Pierson, 212 Mich 659. The description of the option in this case was held sufficient, merely describing the lots as Lots Nos. 831, 833 and 835 North Saginaw Street, not giving the city, county, or state. An extension to this option, however, was given which described the property as Lot No. 821 North Saginaw Street, Flint, Michigan. The extension was held to contain a sufficient description.

Mull v. Smith, 132 Mich 618. Holding as description, the Burns Farm sufficient.

Austin v. Dolbee, 101 Mich. 292 (294).-Holding that a deed which describes the land as all my right title and interest in and to my father's estate at law in the S. S. Austin Est. was sufficient to convey the real estate. Bawden v. Hunt, 123 Mich. 296. Where a description in a deed conveyed to the grantee a house situated on a certain lot correctly describing the lot was held that the title of the lot passed with the house. Garvey v. Pankhurst, 127 Mich. 370. Holding that where one person wrote to another making them a certain prop osition to purchase his place, using the expression my place in the letter and the purchaser pursuant to such proposition went on the place, and worked it, held that the contract was sufficient compliance with the statute of frauds. Francis v. Barry, 69 Mich. 311, 37 N. W. 353. Where a description of property described as the "Schoolcraft Store" was held sufficient. Slaver v. Breese, 36 Mich. 77; Wiley v. Lovely, 46 Mic,h. 83; Crooks v. White-ford, 47 Mich. 286; Huron Land Company v. Robarge, 128 Mich. 686. Any description of property whether by street numbers or by a well known name, or other designation by which identity of the premises can be ascertained will be sufficient. United States v. Sutherland, 60 U. S. (19 Howell), 363, 15, L. Ed. 666. A tract of land known by name of El Cajon near the mission of San Diego is not void for uncertainty. The same rule is applied in case of Phelan v.

In some of the later cases a tendency is noted on the part of the courts to restrict the somewhat liberal rule announced in the text by requiring a more complete description of the real estate sought to be conveyed.39

Poycreno, 74 Calif. 456; Martin v. Lloyd, 94 Calif. 195; Veyer v. Mound City Association, 97 Calif. 659; Hilberg v. Creer, 172 Mich. 505-7. Holding that a description of land by street and house number is sufficient. It is only essential that the description shall identify the property, and, if this result can be attained by proving the identity and location of the land in the description, it will be sufficient. Lyman v. Gedney, 114 111. 386. Eg-gleston v. Wagner, 46 Mich. 610, 10 N. W. 37. Where a description of property as, "My title and interest in land," belonging to a certain business was held sufficient. Anderson v. Baughman, 7 Mich. 69. Where a mortgage described the land conveyed as lot 4 of block 1 of the La Fontain farm lying south of the River Road and fronting on Detroit River being now used and occupied with the steam sawmill thereon by the parties of the first part and it appeared that that portion of the La Fontain farm had been platted into four lots or plats which had not been subdivided and that the mill was situated on one No. 4 of the plat and the others were fenced in, used and occupied by the mill, held that the works of Block 1 of this description should be rejected and the mortgage held a valid lien upon lot 4 according to the evident intent of the parties.

39. Clark v. Holman, 204 Mich. 62. In this case the following memorandum was signed by the defendant at an auction sale of real estate:

"This is to certify that I have this day bought through The Louisville Real Estate & Development Co. Lot No. 1, 2, 3 in Block 3, according to the official plan of..........

..................for which I agree to pay $225.00 on the following terms:

..........................cash on day of sale, balance ....................................................

"Date Aug. 12, 1914.

"Signature, Geo. Holman." "Witness:.............................................."

Thereafter plaintiff tendered to the defendant a deed to the lots in question and demanded payment of one-third of the purchase price and the execution of notes for the balance. Performance being refused by the defendant, this suit was brought to recover the sum of $675.00. The plea was the general issue. The lower court directed a verdict in favor of plaintiff. The Supreme Court held that the memorandum was insufficient to support the plaintiff's action.

In Miller v. Beardslee, 175 Mich. 414, a bill was filed to cancel a deed on the ground that the deed as delivered contained no sufficient description of the premises; the real estate is described therein as follows:

"All of certain pieces or parcels of land situate and being in the Township of Oakland, County of Oakland and State of Michigan, and described as follows, to-wit: The west half (1/2) of the northeast quarter (1/4); also the east half

(b) The price, time, and manner of payment must be specified.40

(c) If the preliminary agreement refers to a subsequent agreement to be later executed the terms of such subsequent agreement must be clearly stated.41