Law School Case Brief
Blinn v. Beatrice Cmty. Hosp. & Health Ctr., Inc. - 13 Neb. App. 459 (Neb. Ct. App. 2005)
Promissory estoppel requires that reliance be reasonable and foreseeable.
Appellant employee began his employment with appellee employer as an at-will employee in 1993. In 2002, after receiving a job offer elsewhere, the employee approached the employer with an offer of resignation; he wanted some assurances that he had job security with the employer before rejecting the other job offer. According to employee, his supervisor and the employer assured him that the employer had "at least five more years of work" for him. The employee took the statement to mean that he had a contract with the employer for "at least five years." The employee then rejected the job offer. The employer terminated the employee in 2003. Appellant employee brought suit against appellee employer seeking damages arising out of the employer's termination of the employee's employment. The district court granted summary judgment in favor of the employer.
When a promise is not definite enough to constitute an offer, but the promisee reasonably and foreseeably relies on that promise, has he established a claim for promissory estoppel?
The appellate court found that the trial court erred in granting the employer summary judgment, finding that evidence adduced and not objected to by the employer raised a genuine issue of material fact concerning whether the employer offered to extend the employee's employment either until he chose to retire or for at least five years, and that such a modification of the employee's employment status would not have violated the statute of frauds because it could have been fully performed within one year. The appellate court also found that a genuine issue of material fact was raised concerning the employee's promissory estoppel claim. The alleged oral agreement to modify the employee's at-will employment status was not too indefinite to prevent a theory of promissory estoppel. At a minimum, genuine issues of material fact existed concerning the elements of promissory estoppel. In this case, the relevant elements were (1) whether the employer made a definite promise of employment to the employee, which the employer reasonably expected or should have expected would induce the employee to refuse the job offer and remain employed; (2) whether the employee was, in fact, induced to act by such offer; (3) whether the action taken by the employee was detrimental to him; and (4) whether justice requires that the employer reimburse the employee for damages incurred as a result of the promise of employment. As such, summary judgment was inappropriate. The judgment was REVERSED, and the case was REMANDED for further proceedings.
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