52 (1994)[1] was a North Carolina Court of Appeals case dealing with a breach of contract.

Buffaloe had previously rented the barns based on verbal agreements.

Both parties agreed to sell the barns in four annual installments based on a handshake deal without any written documentation.

Buffaloe sent them a personal check with the purpose written in the subject line but they sent it back to him as they had found a buyer willing to pay more.

Additionally, the UCC calls for a written agreement to accompany the sale of goods in certain instances.