Jarboe v. Landmark Cmty. Newspapers - 644 N.E.2d 118 (Ind. 1994)

Rule:

The doctrine of promissory estoppel may be available to an at-will employee, but the remedy is limited to damages actually resulting from the detrimental reliance and will not include the benefit of altering the employment status from an at-will relationship to a permanent one which requires just cause for termination.

Facts:

Plaintiff employee filed suit against defendant employers, alleging wrongful discharge based on a breach of an oral employment contract and promissory estoppel. The employee's supervisor allegedly told the employee to take all the time he, the employee, needed to recover from a knee operation and that the employee's job was secure. The employee was later terminated when he was unable to return to work in the allotted time. Applying the employment-at-will doctrine, the circuit court granted summary judgment for the employers. The appellate court reversed the judgment as to the promissory estoppel claim, but affirmed as to the contract claim. Plaintiff sought review. 

Issue:

Was the doctrine of promissory estoppel available to an at-will employee? 

Answer:

Yes.

Conclusion:

The court noted that Indiana courts recognized a limited application of the doctrine of promissory estoppel in claims for damages resulting from a plaintiff's detrimental reliance on a defendant's promise of employment. Thus, in this case, the court held that the doctrine of promissory estoppel may be available to the plaintiff at-will employee, but the remedy was limited to damages actually resulting from the detrimental reliance and will not include the benefit of altering the employment status from an at-will relationship to a permanent one which required just cause for termination. Thus, any lost-wage damages to which plaintiff may be entitled on a theory of promissory estoppel would be limited to those incurred between the date of actual termination and the date of his release to return to work, less any disability benefits actually received by the plaintiff for this period of time.