
Vokes v. Arthur Murray: Fraud as a Formation Defense
Yale law professor Ian Ayres works through Vokes v. Arthur Murray, a case about an elderly widow who paid for thousands of dollars in dance lessons after instructors repeatedly told her she had natural talent and was becoming a better dancer. Ayres uses the case to explain fraud as a formation defense in contract law, distinguishing actionable misrepresentation of fact from mere opinion or sales talk (puffery), and asking why courts treated the instructors' flattery as the former rather than the latter given the imbalance of expertise between the parties. The lecture is part of Ayres' American Contract Law course, originally taught at Yale and adapted for Coursera, and sits within a unit on special controls on promissory liability. It is a short, focused case analysis rather than a broad survey, aimed at students already working through the formation-defenses unit.