Virtually all residential real estate sales are done so using the standard California Association of Realtors (CAR) forms. An offer is usually made by the use of a California Residential Purchase Agreement and Joint Escrow Instructions (RPA-CA) form as are counter-offers and amendments. Some of our broker clients have asked our real estate attorneys whether an oral revocation of a written offer is enforceable. California law seems to be well settled that an oral revocation of a written offer is sufficient. See
Cal. Civ. Code § 1587; see also Bellasi v. Shackelford
, (1962) 201 Cal. App. 2d 265, 267-68 (“An offer is revoked by communication of notice of revocation… An oral communication meets this requirement.”) (citing
Cal. Civ. Code §§ 1581, 1587); see also Brown v. Labow
, (2007) 157 Cal. App. 4th 795, 817 (“It is well established that a written offer may be orally revoked
.”) (Emphasis added.) Under general principles of contract law, parties to a contract can agree that a revocation be in writing, but absent such a provision or where the contract is silent, an oral revocation seems to be sufficient.