In the case of Rudinsky v. Green Light Realty, the Arizona Court of Appeals has upheld the dismissal of a lawsuit by a real estate saleswoman who sued Green Light Realty for breach of an alleged oral agreement to pay her commissions.  Rudinsky testified that she was entitled to commissions on all sales to buyers whom she introduced to Green Lights’ developer/customers.  Not only to ‘first generation’ buyers, but also to second or third generation buyers, those buyers referred by her original buyers.  The Court of Appeals agreed that because this agreement was not in writing it was not enforceable.  Of the types of contracts that must be in writing under Arizona’s Statute of Frauds, this alleged oral agreement violated the provision that oral contracts which cannot be completed within one year must be in writing to be enforceable.  Because this contract, according to Rudinsky, would go on indefinitely into the future, so long as she was able to trace the ‘genealogy’ of the buyers back to her, it was not a contract that could be performed within one year and because it was not in writing, her claim was dismissed.