Michie v. Board of Trustees

847 P.2d 1006, 1993 Wyo. LEXIS 38, 1993 WL 49438
CourtWyoming Supreme Court
DecidedMarch 1, 1993
Docket92-161
StatusPublished
Cited by17 cases

This text of 847 P.2d 1006 (Michie v. Board of Trustees) is published on Counsel Stack Legal Research, covering Wyoming Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michie v. Board of Trustees, 847 P.2d 1006, 1993 Wyo. LEXIS 38, 1993 WL 49438 (Wyo. 1993).

Opinion

MACY, Chief Justice.

Dr. and Mrs. David F. Michie appeal from a district court order which granted a summary judgment adverse to their claim that the Board of Trustees of Carbon County School District No. 1 should be estopped from terminating their coverage under the school district’s group health insurance plan.

We affirm.

The Michies raise a single issue for our consideration:

Is an enforceable contractual obligation a necessary element of a claim for promissory estoppel?

Dr. Michie served as an elected member of the Board of Trustees from 1981 to December 1988. In the fall of 1984, the Board of Trustees requested the school superintendent to investigate whether the board members could legally participate in the school district’s insurance plan. The superintendent contacted the school attorney for a legal opinion.

At a Board of Trustees meeting held on October 11, 1984, the school attorney opined that the board members could participate in the insurance plan without violating Wyo.Stat. § 21-3-107 (1992) 1 as long as each participant paid his own premium. The superintendent also informed the board members that participation in the *1008 insurance plan would not be limited to their terms on the Board of Trustees. The minutes reflect that the Board of Trustees took the following action:

Smith then moved to allow board members to be put on the group insurance program at their own expense. Motion seconded by Michie and carried.

Dr. Michie canceled his family’s health insurance policy shortly after the aforestated action was taken and enrolled under the school district’s insurance plan effective December 1, 1984. John Smith enrolled sometime later.

Dr. Michie and Mr. Smith did not serve on the Board of Trustees after 1988. On March 23, 1989, the then-elected Board of Trustees voted unanimously to disallow participation by all board members, past or present, in the school district’s insurance plan. The school district’s business manager subsequently informed Dr. Michie and Mr. Smith of the Board of Trustees’ action. Dr. Michie informed the Board of Trustees by letter that he intended to seek “redress and relief.”

The Michies filed a complaint against the Board of Trustees in the United States District Court for the District of Wyoming on April 3, 1991. They advanced four claims by way of this complaint. First, the Michies asserted that the Board of Trustees breached an alleged contract to allow them to participate in the insurance plan until they were eligible for Medicare. Second, the Michies claimed that they should be allowed to continue to participate in the insurance plan under the principle of promissory estoppel because Mrs. Michie, a diabetic, had been unable to procure adequate insurance privately. Third, the Michies stated a claim under 42 U.S.C. § 1983 for the deprivation of property without due process. Finally, the Michies requested that punitive damages be awarded for the Board of Trustees’ alleged willful and wanton misconduct.

The Board of Trustees moved for a summary judgment after it answered the complaint and conducted discovery. At the hearing on this motion, the Board of Trustees argued, among other things, that any obligation undertaken by the 1984 Board of Trustees was not enforceable against a subsequent Board of Trustees as a matter of public policy unless it could be shown that the obligation was “reasonably necessary or of a definable advantage” to the school district. Mariano & Associates, P. C. v. Board of County Commissioners of County of Sublette, 737 P.2d 323, 332 (Wyo.1987).

The federal district court ruled in its summary judgment order that the Michies could not maintain their 42 U.S.C. § 1983 action because they possessed no property right, under either contract law or equity, to continue to participate in the school district’s insurance plan. The court made this ruling upon determining: (1) that the 1989 Board of Trustees effectively voided the alleged contract because the Michies failed to demonstrate that it was either “reasonably necessary or of a definable advantage” to the school district; and (2) that equitable remedies, being discretionary in nature, do not give rise to legal rights cognizable under 42 U.S.C. § 1983. The court accordingly granted a summary judgment in favor of the Board of Trustees on the Michies’ breach-of-contract and 42 U.S.C. § 1983 claims. It also dismissed the Michies’ promissory estoppel and punitive damages claims, without prejudice, for lack of subject matter jurisdiction.

The Michies renewed their promissory estoppel claim against the Board of Trustees by filing a complaint in state district court on January 13,1992. Once again, the Board of Trustees moved for a summary judgment after answering the complaint. The court heard argument on this motion on April 27, 1992, and thereafter issued its decision letter. In its decision letter, the court explained that the Board of Trustees was entitled to a judgment as a matter of law because the Michies failed to demonstrate “the existence of a contract or enforceable promise under which estoppel could be grounded.” The court subsequently filed an order of summary judgment from which this appeal is taken.

The Michies concede on appeal that the federal district court determined that they *1009 did not have an enforceable contract with the school district because any contract which might have existed was effectively voided by the 1989 Board of Trustees. They contend, however, that the state district court erred as a matter of law by granting a summary judgment on their promissory estoppel claim, apparently on this basis. The Michies argue that an enforceable contractual obligation is not an element of a promissory estoppel claim.

We agree that a claim for promissory estoppel is not dependent upon the existence of a promise which is enforceable under traditional contract principles. See McDonald v. Mobil Coal Producing, Inc., 789 P.2d 866 (Wyo.1990), on reh’g, 820 P.2d 986 (Wyo.1991). By definition, promissory estoppel is an equitable remedy for detrimental reliance upon a promise which does not rise to the level of a formal contract. As explained in Restatement (Second) of Contracts § 90(1) (1981):

A promise which the promisor should reasonably expect to induce action or forbearance on the part of the promisee or a third person and which does induce such action or forbearance is binding if injustice can be avoided only by enforcement of the promise.

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Bluebook (online)
847 P.2d 1006, 1993 Wyo. LEXIS 38, 1993 WL 49438, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michie-v-board-of-trustees-wyo-1993.