Promissory estoppel is now a mature doctrine

Promissory estoppel is now a mature doctrine â€Å"Promissory estoppel is now a mature doctrine. Its role is to mitigate some of the harshness of the doctrine of consideration by protecting those who reasonably rely on promises. Its full potential can only be reached if the court permits its use not merely as a shield, but as a sword, where appropriate. The decision of the Court of Appeal in Baird Textile Holdings Ltd v Marks and Spencer plc [2001] therefore represents a missed opportunity to clarify and modernise the law. Promissory estoppel is an important tool in equity to create fairness within contract law. It deals specifically with consideration, which as a doctrine holds the parties that have entered into a contract to which they both intend to be bound. Therefore the parties must have the capacity to be bound to the contract; as well as the intention to be bound by the contract. There must be a value to amount to consideration, which does not necessarily have to be monetary[1]. Consideration can be a right, interest, service, benefit to one party and sufficient detriment to the other party. [2] Consideration does not have to be equal on both sides; one party may only leave a nominal amount of consideration[3] As long as there is sufficient intention and the terms are not vague then the law will not get involved in business dealings; therefore the courts will infer intention[4]; as long as the consideration for that particular business dealing illustrates that there is sufficient consideration. [5] Insufficient consideration is any act where the duty is already imposed by law or a valid contractual duty. However, there are exceptions to the rules, because consideration at times can be deemed as far too harsh. The case of Williams v Roffey Bros[6] held that consideration could be inferred in a pre-existing contractual duty if there was further consideration that could be inferred. For example this case recognized that the contractor would be subject to a significant late charge, if he did not re-negotiate his contract with the subcontractor to finish on time. Therefore the renegotiation of the pre-existing duty saved the contractor a loss of money, which the courts held as sufficient consideration. However, in the case of paying a partial debt there can never be consideration. The rule in Pinnel’s Case[7] was confirmed in the case of Foakes v Beer[8] where it was held that part payment of a debt could be held as consideration because there was an existing contractual duty. The rule in Pinnel’s Case is that promissory estoppel is an invalid action when it comes to the part payment of debt, unless it is paid in full and benefits both parties. The reasoning behind this is that p art payment of debt is inequitable because the person who is supposed to benefit from the consideration is put at a detriment and therefore defeats on of the central tenants of consideration, which one party is at a sufficient benefit whilst the other party is at a sufficient detriment. There are circumstances where promissory estoppel is possible in regards to a reduced payment of a price or fee. The case of Central London Property Trust v High Trees House Ltd[9] is such a case, because the political and social environment was drastically changed. The two parties where a property owner and a business tenant, who then leased the property as flats to other individuals residentially. An agreed business tenancy price came into question during WWII, because of the bombings in London the situation made it impossible for the renter to pay the whole rent due to the bombing and lack of tenants. Here equity stepped and promissory estoppel was used, because it would be unfair to make the rent er pay the whole rental amount due to the circumstances. In addition the agreement by the property owner to accept less due to the WWII inferred intention, because otherwise the landlord would receive no rent because the renter would have vacated the premises; and no other businesses would have taken up the tenancy during the war. This is a very specific scenario, where WWII could have amounted to frustration of the contract, because the war would have made it impossible for the renter to satisfy the contract and an act of war is outside his ambit of control. After the High Trees case the courts extended the doctrine of promissory estoppel in the case partial full partial payment of a debt; however if it were revealed that the re-negotiation was due was an action of duress that forced the creditor to agree to the new credit agreement then equity could not step in with the doctrine of promissory estoppel. One such case that illustrates that equity will only aid those with clean hands is the case of D C Builders v Rees[10] where Rees discerned that the building company was in financial distress and tried to use this to her advantage by offering a smaller payment in full or nothing. This amounted to duress, because the knowledge that Rees had of the problems that D C Builders were facing was used as a sword against a fair and equitable outcome. The key factor that surrounds the doctrine of Promissory Estoppel is that it originates out of equity and aims to create a just outcome, as in the High Trees Case. In the case of D C Builders the use of Promissory Estoppel was for unjust purposes and equity could not aid Rees, because an injustice would occur. High Trees is the case that the modern doctrine of Promissory Estoppel has developed from; however it was the Hughes Case that the doctrine originated from, where a landlord’s actions gave the tenant contrary belief in the events surrounding a notice to repair. Tool Metal Manufacturing Co Ltd v Tungsten Electric Co Ltd[11] case allows for suspension of payment to be reverted back to active payment as long as reasonable notice is given. This also means with the reasonable notice that the creditor can also receive compensation for the suspended payments; therefore ensuring that there is not a case of part payment of debt, because the interest can keep running. The only exception to this is an agreement of an early settlement, with a lump sum that is considered reasonable by both parties. The Tool Metal Case and the Hughes Case point to the doctrine of promissory estoppel being a shield and not a sword of equitable justice, because it believes that consideration plays an essential part of contract law. To eradicate the harshness of consideration may allow individual like Rees in the D C Builders Case to use Promissory Estoppel for unfair and unjust purposes. However, the High Trees Case that is the key case for the modern doctrine of Promissory Estoppel seems to be pointing in a different direction, i.e. that the doctrine is a sword against the harshness of consideration. In this case WWII made it impossible for the original contract to be kept to, hence the parties re-negotiated during this period. The case of Coombe v Coombe[12] argued that the doctrine in High Trees could not be identified as a sword against the doctrine of consideration; rather it can only be used as a defense to an action and in the interests of justice. The cases of Re Wyven Developments[13] an d Evenden v Guildford City AFC[14] argued that Coombe v Coombe was incorrect and that the doctrine of Promissory Estoppel could be used as a sword; as well as a shield if justice and equity dictated. The Coombe approach makes sense by ensuring that the rules surrounding contract law are upheld and ensuring that certainty in contracts remain; otherwise there would be a mass confusion where courts could get too involved in business contracts. English law is based on a laissez faire system, where business dealings should be free from the ministrations of parliament and the courts; as long as just and both parties were capable to enter the contract. As Mitchell argues, parties enter a contract with specific expectations and to turn these upside down would be a breach a fundamental principle of contract law: While we could dismiss this as assimilating reasonable expectation with contractual rights, and therefore making the appeal to reasonable expectation redundant, it is clear that many appeals to reasonable expectation rely upon an institutional or contract law-based source for such expectations. Reiter and Swan, for example, write that '[t]he assumption is that the fundamental purpose of contract law is the protection and promotion of expectations reasonably created by contract'. If 'contract' here is taken in a legal, rather than a social sense, then the utility of reasonable expectations as a counter-contractual reference point is in danger of disappearing.[15] Therefore in the light of the essential principles of contract law and the doctrine of consideration the decision of Baird v MS[16] would have been the correct decision, otherwise there would be a free for all for parties to argue that the contract is unjust and flagrant actions of Promissory Estoppel would occur. However, Promissory Estoppel would still remain as a defense in cases where the situation dictated that there would be an unjust outcome if the contract was upheld in its present form. The case of Baird v M S, Baird used Promissory Estoppel as an action to enforce what Baird classed as an unwritten contract. In other words Baird was arguing that the long term relationship between the two created a reasonable expectation that there was an ongoing business relationship, which could only be altered or terminated with reasonable notice; as per the Tool Metal Case. The Court of Appeal however decided against this approach, because the reason that M S did not enter a written co ntractual agreement was for flexibility and the option of changing suppliers if market forces dictated this route. Also the Court of Appeal stated that the lack of a (legal) contract was determinative for the court. The estoppel claim was also thought likely to fail, since estoppel cannot be used to create a cause of action. It was remarked that, despite the close relationship between the parties, 'businessmen must be taken to be aware that, without specific contractual protection, their business may suffer in consequence.[17] However, this argument seems to be very one-sided, because as with the High Trees Case the situation in Baird v M S does indicate that there was intention to create some form of business and contractual relationship that benefited both parties. In fact the long history of Baird supplying the goods could be inferred as terms and conditions of the contract; however the lack of a written contract seems to be an excuse for the Court of Appeal to open up Prom issory Estoppel as an action; as opposed to just a defense. Therefore, as Mitchell argues the decision in Baird v M S could be taken either way because both sides were arguing certainty of contracts and reasonable expectation; however the determining factor not to find a contract was because of public policy reasons NOT to make Promissory Estoppel a cause of action (a Sword) and open the floodgates to further actions: One can see how a 'reasonable expectations' argument can be used to support Baird or M S, but each relies on a different basis for the reasonable expectation. Baird will have non-contractual reasonable expectations concerning the parties' mutual obligations, based upon their experience of the previous thirty years. M S, on the other hand, have reasonable expectations based on their strict legal rights, and supported in the judgement, that there is no contract and hence the relationship can be terminated at will-an institutional interpretation of reasonable expectation†¦ This result does not support the attempt to make contract law more sensitive to the social dimension of agreement-making, but undermines it by privileging the legal framework in the resolution of the dispute.[18] Bibliography: J. Beatson (2002) Anson’s Law of Contract 28th Edition, Oxford University Press Hooley (1991) Consideration and Existing Duty JBL 19-35 David Kelly, Ann Holmes Ruth Hayward (2002) Business Law 4th Edition, Cavendish Ewan McIntyre, (2004) Business Law, Longman McKendrick, 2005, Contract law, text, cases and materials, second edition, Oxford University Press Mitchell, 2003, Leading a Life of its own? The Roles of Reasonable Expectation in Contract Law, OJLS 23 639 Stallworthy (1994) Case Comment: Variation of Contracts, ICCR 5(7) Chris Turner (2004) Unlocking Contract Law, Hodder Arnold Footnotes [1] Currie v Misa (1875) LR 10 Ex 15 [2] Combe v Combe (1951) 2 KB 215 [3] Chappell Co Ltd v Nestle Co Ltd (1960) AC 87; Mountford v Scott (1975) [4] White v Bluett (1853) 23 LJ Ex 36 [5] Collins v Godefroy (1831) 109 ER 1040 [6] [1991] 1 QB 1 [7] (1602) 5 Co Rep 117a [8] (1884) 9 App Cas 605 [9] [1947] KB 130 [10] [1966] 2 KB 617 [11] [1955] 1 WLR 761 [12] [1951] 2 KB 215 [13] [1974] 1 WLR 1097 [14] [1975] QB 917 [15] Mitchell, 2003, Leading a Life of its own? The Roles of Reasonable Expectation in Contract Law, OJLS 23 639 [16] [2001] unreported [17] Mitchell, 2003, Leading a Life of its own? The Roles of Reasonable Expectation in Contract Law, OJLS 23 639 [18] Mitchell, 2003, Leading a Life of its own? The Roles of Reasonable Expectation in Contract Law, OJLS 23 639

Drama Coursework †Response Phase Essay

As part of our drama course we are studying the play â€Å"blood brothers† by Willy Russell. Blood Brothers is about twins who were separated at birth because their mother could not afford to keep both. As they grow up they meet, become friends and eventually blood brothers. However they both fall in love with the same girl and this conflict ultimately leads to their tragic deaths. First we read the play blood brothers as a class, then our teacher, Mrs O— asked us to choose and then act out three or four scenes which we, as a group thought were most important. In my group were S—, G— and N—. The first scene we chose was when Mr Lyons asks Mrs Johnston to give away one of her babies, we thought this was a crucial moment in the play because in this scene we see how the brothers first got separated. We also see the differences between the middle and the working class people, which was important as it is a main theme in the play. I was playing Mrs Lyons and N— was playing Mrs Johnston. We started our performance with a freeze frame; our freeze frame was useful as it showed the audience what scene we are going to perform. Nicola, playing Mrs Johnston was looking down holding her stomach as if she was pregnant. I was standing on her side holding a bible pushing it towards her. We wanted to show the part where Mrs Lyons was asking Mrs Johnson to make a binding agreement, we used facial expressions to show which characters we were trying to portray. As I was Mrs Lyons, I stood with a smug arrogant look to show that I was the wealthy one, while N— was looking sad, worried and a little scared. Our role-play started with Mrs Johnston working and Mrs Lyons coming in to see how she was doing. As Mrs Lyons I spoke with a posh accent boasting about how big my house is and looking down at N—-. We used thought tracking to get inside the characters mind and see what they are really thinking. When N—- was telling me about how she can stop getting pregnant and I can’t have any babies thought tracking was useful as I got to show the audience how I was actually jealous and thought that the babies would be better off with me. We also used it to show that N— did not like Mrs Johnston showing off and thinking she was better then her. After the visit to the doctors, N—- acted like she was nervous and panicking that the welfare will come and take her children away and worried about how she would cope with two more babies. At this point I used thought tracking to hint to the audience that I was thinking about asking for a baby. When I did ask for a baby I started to act more mean and scary grabbing hold of N—- and begging her to give me a child to show how desperate Mrs Lyons was to have a baby. N—- used thought tracking to show the audience that she was thinking about agreeing to give me a baby and also to show that she was a little scared of me. I was shouting at her doing all I could to make her agree and getting a bible and forcing her to make a binding agreement. We also used hot seating in our performance; this helped the audience to get to know more about the characters. Our teacher, Mrs O— first asked us questions and we had to answer staying in character. The audience got to know about how N—-‘s husband left her and how she has to look after all the kids by herself. We also used it to show that she was considering giving a child a baby to Mrs Lyons, as she could not afford to have any more kids. The hot seating helped me show how Mrs Lyons’ evil side and how she did not care if it was wrong all she wanted was a child and she does not care how she gets it. For our second scene we choose the part when the brothers meet for the first time. This we thought was another key scene as it shows how they meet and become blood brothers, not knowing that they were actually real bothers. G— was playing Edward and S— was playing Mickey. In this scene we see how better off the rich one, Edward is that Mrs Lyons is looking after him. The freeze frame for this scene was when the two boys were crossing fingers and Mrs Lyons in the background. We made it clear what scene they were going to perform was when they first meet because it was the part when they became blood brothers. They were both smiling and happy to have made a new friend while Mrs Lyons stood in the background with her arms crossed looking angrily at the two of them. We added a bit of comedy to this part because they are seven year olds and we wanted to show that. Shikira was sitting on her own making funny gun noises looking very scruffy and G—- walks in acting very posh. When S— taught him swear words he was shocked and amazed at all the â€Å"smashing† things that S— says. We used thought tracking to show how G— had never meet a boy like him but actually liked him. The hot seating gave the audience a chance to see that G—- has not got a lot of friends as they all bully him but not S—-. They audience also got to see that S—- never meet a posh boy like him but they became friends. In the second group were K—, M—, M— and B—-. The first scene they done was when Mrs Johnston gives one of her babies away to Mrs Lyons. K—- was playing Mrs Johnston and M— was playing Mrs Lyons. Their freeze frame was of K—- down on her knees scrubbing the floor and M—- crossing her arms looking down at her. It was obvious what scene they were going to do and what characters they were playing by using body positions and facial expressions. M—- looking arrogant and like a snob and showing how she thinks she is above K—– just because she is richer. Their performance was very well organised and they all knew what they were doing. M—- was very good at acting arrogant and as K—– cleans she was looking down at her and used good thought tracking to show how she felt. K—– did well as Mrs Johnston acting like she is happy to work for her but suing thought tracking show that she secretly did not like Mrs Lyons and that created tension between the two of them. I thought that they lacked thought tracking as the play went on and could have added more towards the end of their performance. Their use of hot seating was good; although I thought when they answered they could have gone into more detail and let the audience find out more about their characters. From the hot seating we learnt that M—– does not think its wrong to take K—-‘s baby and that K—- has no money to look after any more children. I thought that M—– could have improved her performance by added more thought tracking and speaking louder but I thought she did well at showing she was Mrs Lyons by the way that she spoke and her attitude towards K—–. K—– acted confidently, and used good thought tracking to show what she was thinking at the start of the play. She would have improved her performance by adding more detail to her answers in the hot seating and more thought tracking at the end of their performance. In the third group were G—-, T—–, S—- and T——. One of the scenes they acted out was the last scene; this is an important scene in the play because it was when Mickey finds out about Linda’s affair with Edward. Mrs Johnston’s secret deal with Mrs Lyons is also reviled and both brothers end up dead. T—– played Mickey, C—— was Edward and Grace played Mrs Johnston. Their freeze frame was off the end of the play when Mickey and Edward were dead. T—– and C—- were lying down on the floor dead and G—- was standing over them. They did well to show the tragic ending of the play and g—— used good facial expressions to show that she was shocked and upset at what had just happened. She stood with her head slight down and looked like she was crying out in disbelief. They stared with Mickey who was played by T—— going crazy wandering around the stage looking for the pills. She used thought tracking to tell the audience what she was looking for and how she angry she felt that she did not have them. When she found out about Linda and Edward’s affair she acted good and confidently showing how angry and frustrated she was. She used thought tracking telling the audience how she was thinking out killing him when she went to get the gun before storming out to find Edward. C—– playing Edward was doing his job making a speech acting normal when suddenly T—— barges in pointing a gun in his face. The use of hot seating at this moment let the audience know how scared Edward was and how T——- was not thinking straight and how she was just angry. I thought that this group also could have spoken in more detail to explain to the audience how they feel. At this moment G—— runs in trying to stop T——. She used thought tracking to say how she was thinking of telling them the truth. G—– trying to stop Mickey shouts out to not to kill Edward because they are brothers. But this just makes T—- even more angry thinking that he could have ended up like C———- with a good job and a great life. G—- in a final attempt to stop Mickey pushes his hand but the gun shoot and kills Edward. The police then shoot T—— and she falls to the floor, leaving G—– in crying in shock. I thought that in this part they could have been more organised and put more thought tracking in but all in all they had a great performance.

Death of a Salesman Essay

Discuss the role and importance of the first â€Å"flashback† scene in Death of a Salesman. This scene is the first in the play which gives us any real insight into the past of Willy, the protagonist of the play. Its purpose is to show the audience of some of where Willy went wrong; we see some of his mistakes through his memories of his own past. We see the way that he treated his sons, and how this relates to what they are like now; we witness the difference between what the impression of himself he gives and the failure he really feels; we discover his affair with the woman, why he had it, and the terrible guilt that overhangs him because of it. This then explains some of the tension and unhappiness that we have seen so far in the play. This, though, only takes us so far; we do not learn the full story, of why he and his son do not now share the bond we see in the flashback scene, and of why he becomes so depressed. He does not want to see the truth – he is not ready to realise where he went wrong. The scene gets more and more dramatic as it gets on. At first, it shows us an idyllic, happy time; Willy is apparently a fantastic success, who is idolized by two loving sons. The eldest son, Biff, is popular with the others at school and with girls, a great sportsman, and generally â€Å"well liked†. They all live in a beautiful house, surrounded by fields. But we then find about Biff stealing and then his poor academic achievement, that Willy lies about how successful he really is, and finally the affair with the woman before the whole thing spirals out of control and turns into some kind of terrible nightmare. We move into Willy’s memories using a number of stage effects – the lights brighten, we hear soft music, possibly flute music, and the background turns from the harsh orange of the brick apartments to the cool green fields of the countryside. This has a calming, nostalgic sense on the audience, who are therefore encouraged to share Willy’s feelings at the start of the flashbacks; we feel that we are entering a happier, more pleasant past. When he talks about himself to his sons, he presents himself as a great success; he uses lots of boxing language, such as â€Å"knocked ’em cold† and â€Å"slaughtered them†. He knows that his sons praise athletic ability, and so likens himself as a boxer, and a winner. Phrases like â€Å"open sesame† suggest that success in his glamorous job comes easily to him; he is a person who takes coffee with the Mayor of Providence, who deals with â€Å"the finest people†. But Willy, although he does not realise it, does a lot of harm to his sons through the lessons that he teaches them. In congratulating his son on taking the ball from school, he teaches them that, so long as you are â€Å"well liked†, you do not need to obey the rules, that popularity is more important than honesty and integrity. He also teaches them that the key to success is not in schoolwork, but in being popular, and in turn, the key to being popular is through good looks and sporting skill. He tells them that Bernard will not go far, because, although he is good academically, he is not well liked, but Biff, being as popular as he is, will become a success. Bernard is â€Å"anaemic† and a â€Å"pest†, whilst he is clearly proud of his own son, Biff. This, of course, is unrealistic – Bernard’s hard working attitude is more likely to render him a success than Biff’s sport aptitude and looks, and we see this in the play. In the next episode, with Linda, what he tells her contrasts greatly with the story he told his two sons. This does not happen immediately though; firstly he tells her he â€Å"was sellin’ thousands and thousands†; then he says he sold â€Å"five hundred gross in Providence and seven hundred gross in Boston†, before revealing that he actually sold â€Å"roughly two hundred gross on the whole trip†. When he is talking to his sons, he is trying to gain their love and respect, but he knows that he already has Linda’s, and so does not try to impress her. After claiming to his sons that he is â€Å"well liked†, he reveals to Linda that the other sellers laugh at him behind his back, and refer to him as â€Å"walrus†. He greatly exaggerates his successes; his earlier claims of easy access to wealth contrasts with his resignation that he has to be â€Å"at it, ten, twelve hours a day†. Linda is lovingly loyal and caring to Willy; she accepts and is used to his exaggerations. She patiently ignores the lies, and awaits the true answer to her question. She attempts to comfort him and make him feel good about himself, to display her love for him. When he tells her that he talks too much, she replies â€Å"you’re just lively†. She tells him that he is, to her, â€Å"the handsomest man in the world†. We are then presented with the Woman from Boston, whom Willy has the affair with. Firstly, we hear her laugh, progressively loudening, whilst the Willy continues his conversation with Linda. She appears on stage through the use of a scrim, a fabric sheet which, with the use of lighting, can make whatever is behind the scrim gradually fade onto the stage. The use of the scrim and the laughter is reminiscent of a haunting ghost. This makes the audience feel like this is not a welcome memory; it plagues Willy’s thoughts like a ghost, a memory Willy would like to be rid of, but cannot leave behind. The memory of Linda darning some old stockings after he buys this Woman shows the audience his guilt over what he is doing, and we feel some sympathy for him. He appears to be having an affair with this woman simply because it makes him feel respected. He wants someone to laugh at his jokes, to compliment him, and to make him feel that he is not worthless. He looks pleased when she tells him that she â€Å"picked† him. What he has forgotten, of course, that he has the respect he so greatly desires from his wife, Linda. The Woman and Linda both appear on stage simultaneously, which gives us the feeling that although he doesn’t want to between them, he needs both; he has a burning need for attention, which is provided by the Woman, and needs support from Linda. From when he tells Linda to throw away the stockings that she is repairing, the end of the scene becomes less strictly realistic, and more a nightmare, spiralling out of control. Both Linda and Bernard become very out of character, seemingly unceasingly listing problems with his son Biff, despite his cries of â€Å"Shut up! † and â€Å"Get outa here! â€Å". He is dramatically trying to shut out the memories, to prevent him from coming to the realization that Biff was not perfect, and a lot of it was his fault. Willy is in between Bernard and Linda with a verbal onslaught of complaints about Biff. This peaks with an explosion of anger, with Willy telling himself that Biff was not a failure, comparing his son with Bernard. He finally just denies it – â€Å"I never in my life told him anything but decent things†. This scene is not, by any means, simply a memory. Its purpose is to provide us with an insight into the workings of Willy’s mind. It helps us begin to understand how Willy got into the mental state that we have seen in the play. As we have seen, the use of staging, language and structure have all been important for us to begin our understanding. But Willy does not completely confront the whole truth about his son, but he shuns it, leaving us wondering when he will inevitably confront his past mistakes, and how he will react.

Spanish Words for Snow and Winter Weather

An urban legend has it that the Eskimo language has 25 (or many more, depending on the version) words for snow. While the statement is seriously flawed, it does have some truth to it: Living languages, by their very nature, come up with the words or means to describe nearly everything that people talk about and to differentiate among them. While Spanish may not be a language instantly associated with snow — most Spanish-speaking countries are in moderate climates — it has plenty of words and phrases for the white stuff, as this listing shows. Words and Phrases for Snow and Related Phenomena el agua nieve, el aguanieve: sleet, rain mixed with snowel chubasco: intense snow showerla conchesta: large snowdriftcopo, copo de nieve: snowflakela cornisa de nieve: cornicela cubiera de nieve: snow covercubierto de nieve: snow-coveredel cà ºmulo de nieve: snowdriftla escarcha: frostescarchado: covered with frostel glaciar: glacierla granizada: hailstormel granizo: hail, sleet, hailstone. The verb form is granizar.el granizo blando: soft hail, graupel, snow pelletla helada: frosthelado: (adjective) frozen, very coldel hielo: icela nevada: snowfall; the amount of snow that has fallen over a period of time without interruptionel nevado: snow-capped mountain, snowcap (Latin American usage)nevar: to snow (The Spanish verb is defective in that it is used only in the third-person singular form.)la nevasca: fallen snow, snowfall, snowstorm, blizzardla nevazà ³n: snowstorm (word used in parts of South America)el nevero: permanent mountain snowfield or the snow in such a snowfieldla nieve : snowla nieve amontanada: driven snowla nieve artificial: artificial snowla nieve derretida: melted snow, snowbrothla nieve dura: crusty snow, packed snowla nieve fresca: fresh snowla nieve fusià ³n: snow that becomes almost liquid when it is skied or slid uponla nieve hà ºmeda: wet snowla nieve medio derretida: slushla nieve polvo: powder snow; a more colloquial term is nieve azà ºcar. meaning sugar snowla nieve primaveral: spring snowlas nieves: snowfallla nieve seca: dry snowla nieve virgen: virgin snowla piedra: hailstone (the word can refer to any type of stone)la rà ¡faga: flurry (the word can also be used to refer to a rain shower)la tormenta de nieve: snowstormla ventisca: blizzardventiscar, ventisquear: to blow snow with a strong wind, to blow a blizzardel ventisquero: snowdrift Spanish Words for Items or Situations Related to Snow aislado por la nieve: snowbound, snowed under, snowed inel alud: avalanchela avalancha: avalanchebloqueado por la nieve: snowbound, snowed under, snowed inla bolita de nieve, la bola de nieve: snowballlas cadenas para nieve: snow chainscegado por la nieve: snow-blindel esquà ­: skiesquiar: to skila motonieve: snowmobileel muà ±eco de nieve: snowmanla quitanieve, la quitanieves: snowplowla raqueta de nieve: snowshoeel snowboard: snowboardla tabla para nieve: snowboardel traje de invierno: snowsuit, winter clothing Translations of English Words or Phrases Using snow Blancanieves: Snow Whitetomarle el pelo a alguien: to do a snow job on someonela nieve, la cocaà ­na: snow (slang term meaning cocaine)el raspado: snowcone (term used in parts of Latin America) Sample Sentences Siguià ³ nevando todo el dà ­a. (It kept on snowing  all day.)Si has llegado a tu destino y continà ºa granizando, no salgas del coche hasta que pare o se debilite la tormenta. (If you have arrived at your destination and it keeps on hailing, dont leave your car until it stops or the storm weakens.)El frà ­o de la noche originà ³ una capa de hielo en el parabrisas. (The cold of the night created a layer of ice on the windshield.)La nieve dura es una de las nieves mà ¡s difà ­ciles de esquiar. (Packed snow is one of the most difficult snows for skiing.)El nieve polvo de Colorado es legendaria. (The powder snow of Colorado is legendary.)Los turistas de la motonieve han llegado a la meta, totalmente agotados pero muy satisfechos. (The snowmobile tourists have arrived at the destination, totally worn out but very satisfied.)Corrà ­amos el riesgo de quedar bloqueados por la nieve. (We ran the risk of remaining snowed in.)Una fuerte nevada cayà ³ en las altas cumbres, donde la g ente llegà ³ a armar muà ±ecos. (A heavy snowfall fell in the high peaks, where people arrived to build snowmen.)