Section 1624 of the California Civil Code specifies a number of agreements that are invalid unless they, or some "note or memorandum thereof", are in writing and signed by the party to be charged or the party's agent.  One of the agreements specified in the statute is "an agreement authorizing or employing an agent, broker, or any other person to purchase or sell real estate, or to lease real estate for a longer period than one year, or to procure, introduce, or find a purchaser or seller of real estate or a lessee or lessor of real estate where the lease is for a longer period than one year, for compensation or a commission".

Denise Tukes claimed that she was entitled to a finder's fee in connection with a sale of real property.  Section 1624 and the want of a written agreement seemingly doomed her case.  The Court of Appeal, however, found that Ms. Tukes could avail herself of an exception:

We are satisfied that Tukes has alleged sufficient investment of time and effort in reliance on the Bennett Trustee’s alleged promise to plead estoppel.

Tukes v. Richard, 2022 WL 2680072. 

The Court of Appeal's exception may actually swallow the whole.  The purpose of the Statute of Frauds is to prevent fraudulent claims by requiring more reliable evidence in the form of a writing and a signature.  Following Tukes, a plaintiff need only allege that he or she worked "really hard" based on alleged oral promise in order to claim a finder's fee.