If Dwayne's new player contract is for, as long as Dwayne Simpson can play water polo, it does not have to be in writing to be enforceable. Per UCC $ 2-201 The Statute of Frauds, contracts that cannot by their terms be performed within 12 months need to be put in writing and signed by the party being charged for the goods or services. (UMGC, n.d. Week 6: Defenses to Formation; Performance, and Breach Part 1, para. 1). Theoretically, Dwayne could lose his ability to play water polo within his first year as a new player or at any time, even if it's likely he will be able to play water polo for longer than his first year. With this technicality, it may be that the better option would be to have a written and signed contract in place rather than a verbal contract, but it is not mandatory. An oral agreement would suffice in this instance because it is possible that the contract can be fully executed within one year. If Dwayne happens to be able to play longer than one year, then the verbal agreement is still fully enforceable