Conrad v. Fields

No. A06-1387, 2007 Minn. App. Unpub. LEXIS 744 (July 24, 2007)

 

RULE:

In actions based on promissory estoppel, relief may be limited to damages measured by the promisee's reliance. In other words, relief may be limited to the party's out-of-pocket expenses made in reliance on the promise.

FACTS:

The judgment awarded the student damages based on promissory estoppel. The facts showed that appellant suggested that the student attend law school and that he offered to pay for her education. The student quit her job to attend law school. Appellant made one tuition payment and then paid nothing more. Affirming, the court held that the student's allegations that she would not have attended law school but for appellant's inducement and assurances that he would pay for her education was sufficient to satisfy the notice-pleading requirements of Minn. R. Civ. P. 8.01 and Minn. R. Gen. Prac. Dist. Ct. 507. Further, each of the elements of promissory estoppel were present. Appellant reasonably should have expected his promise to induce action by the student, the promise did induce such action, and the student was left with a substantial debt when appellant failed to keep his promise. Further, because it would have been unjust to have required the student to pay a debt that she incurred in reliance on appellant's promise to pay the education debt, appellant's promise was enforceable despite the statute of frauds set forth inMinn. Stat. § 513.01(1) (2006).

ISSUE:

If no contract existed between promisor and promisee, can promisor expect to induce an action or forbearance on the part of the promisee?

ANSWER:

Yes.

CONCLUSION:

A promise that a promisor should reasonably expect to induce an action or forebearance is binding on the promisor even without the contract, this is under the doctrine of promissory estoppel. All the elements of the latter was established by Conrad. The court affirmed the trial court's judgment and granted in part the student's motion to strike appellant's brief and index. The court granted that motion to the extent that it related to deposition transcripts and a tax document that were not part of the record on appeal.

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