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Promissory estoppel is defined as a promise which the promisor should reasonably expect to induce action or forbearance of a definite and substantial character on the part of the promisee and which does induce such action or forbearance is binding if injustice can be avoided only by enforcement of the promise.
Plaintiff Meyer Blatt brought an action against a university chapter of a national honorary legal society seeking to compel his admission to membership. He alleged that as a law student he had been induced, by defendants' promises of eligibility for membership if he graduated in the top 10 percent of his class, to work hard, that he had, in fact, finished in the top 10 percent, and that refusal of membership, based on his not meeting certain allegedly inapplicable law review requirements, would affect his professional and economic interests. The trial court sustained defendants' general demurrer to plaintiff's second amended complaint and entered a judgment of dismissal. Plaintiff challenged the decision, arguing that his compliant set forth a justiciable issue and that it sufficiently alleged a breach of contract and promissory estoppel.
By being refused membership to the national honorary legal society, could the plaintiff assert a breach of contract claim and promissory estoppel claim against defendant?
The court affirmed the trial court decision. Plaintiff was not entitled to judicial review of the Order's membership selection policies. Membership in the Order did not give a member the right to practice, did not signify qualifications for any specialized field of practice, and did not affect plaintiff's basic right to earn a living. Plaintiff did not establish that the Order engaged in arbitrary or discriminatory actions. Although plaintiff met the Order's admission requirements, there was no proof that such promises or representations induced action on plaintiff's part. There was no allegation that plaintiff was promised that he would in fact be admitted to the Order if he graduated in the top 10 percent of his class.