Thompson v. Schriver

57 Pa. D. & C.4th 157, 2002 Pa. Dist. & Cnty. Dec. LEXIS 124
CourtPennsylvania Court of Common Pleas, Jefferson County
DecidedApril 11, 2002
Docketno. 483-2000 CD
StatusPublished
Cited by1 cases

This text of 57 Pa. D. & C.4th 157 (Thompson v. Schriver) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Jefferson County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thompson v. Schriver, 57 Pa. D. & C.4th 157, 2002 Pa. Dist. & Cnty. Dec. LEXIS 124 (Pa. Super. Ct. 2002).

Opinion

FORADORA, P.J.,

Currently before the court is the defendant’s motion for judgment on the pleadings dismissing the plaintiffs’ request for expectation damages. The plaintiffs in their amended complaint filed December 11, 2000, claim a cause of action based on a theory of promissory estoppel and breach of contract. Specifically they aver that the defendant had approached them concerning the possible transfer of ownership of his interest in a retail store known as “Amish I.” The plaintiffs in reliance upon this offer did take over the management of the store while the parties continued to negotiate the finalized terms of the agreement. On August 13,1999, before any final agreement was reached and formalized, the defendant, without warning, did dismiss them from the premises. The plaintiffs are now attempting to recover “reliance, expectation and lost opportunity costs.” Complaint ¶21.

Pennsylvania Rule of Civil Procedure 1034 provides the following with regard to motions for judgment on the pleadings:

[159]*159“(a) After the relevant pleadings are closed, but within such time as not to unreasonably delay the trial, any party may move for judgment on the pleadings.

“(b) The court shall enter such judgment or order as shall be proper on the pleadings.”

In determining whether to grant a motion for judgment on the pleadings, courts are confined to considering only the pleadings and any attached documents, and “must accept as true all well pleaded statements of fact, admissions, and any documents properly attached to the pleadings presented by the party against whom the motion [was] filed, considering only those facts which were specifically admitted.” Public Service Mutual Insurance Company v. Kidder-Friedman, 743 A.2d 485, 487 (Pa. Super. 1999). Judgment on the pleadings is proper only where the court finds that the moving party’s right to succeed is established beyond a doubt such that “trial would clearly be a fruitless exercise.” Id.

Currently two issues of law are before the court: (1) Is an action for promissory estoppel limited to reliance damages? (2) Does detrimental reliance constitute the necessary consideration' for the formation of a contract? Each of these issues shall be addressed individually by the court.

I. The Restatement (Second) of Contracts §90 states:

“Promise reasonably inducing action or forbearance

“(1) 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 [160]*160 avoided only by enforcement of the promise. The remedy granted for breach may be limited as justice requires. ”

The Supreme Court of Pennsylvania has articulated the necessary elements for a claim of promissory estoppel as requiring: (1) the promisor made a promise that he should have reasonably expected would induce action or forbearance on the part of the promisee; (2) the promisee actually took action or refrained from taking action in reliance on the promise; and (3) injustice can be avoided only by enforcing the promise. Thatcher’s Drug Store of West Goshen Inc. v. Consolidated Supermarkets Inc., 535 Pa. 469, 476, 636 A.2d 156, 160 (1994).

The plaintiffs argue that damages must be awarded as “justice requires,” therefore no legal restrictions exist precluding the award of more than reliance damages. Plaintiffs rely on the express language of Restatement (Second) of Contracts §90 which states, “The remedy granted may be Limited as justice requires.” Using this language as their basic premise they conclude that a logical extension of this legal principle is that “the remedy granted may be Expanded as justice requires.” Although the plaintiffs concede that in Lobolito Inc. v. North Pocono School District, the Supreme Court of Pennsylvania appears to limit promissory estoppel to reliance damages, the plaintiffs contend that Lobolito is distinguishable from the present case. Lobolito Inc. v. North Pocono School District, 562 Pa. 380, 755 A.2d 1287 (2000). In Lobolito, the court, in its reasoning focused on the existence of losses that were incurred in reliance on defendant’s promise and stated they may be recovered under a theory of promissory estoppel. Lobolito Inc. v. North Pocono School District, 562 Pa. 380, 755 A.2d [161]*1611287 (2000). The defendant argues that the court’s act of limiting damages only to those that were incurred in reliance on the promise is evidence that only reliance damages are recoverable. The plaintiffs argue that the court’s opinion limited recovery to reliance damages because of the preliminary stage of the agreement. In Lobolito, supra, the parties had not yet begun to undertake the actual agreement obligations. Plaintiffs argue that in the present case the parties had actually begun performance and therefore are entitled to damages limited only by the bounds of a fair and just result.

The original point of promissory estoppel was to enable courts to enforce contract-like promises made unenforceable by technical defects or defenses.1 It is axiomatic that in order for an agreement to be given the status of legal enforceability it must contain essential elements, an offer, an acceptance and mutual consideration. PennDOT v. First Pennsylvania Bank, 77 Pa. Commw. 551, 466 A.2d 753 (1983). Promissory estoppel has historically been utilized in instances where one of these essential elements is not present. “[T]he phrase ‘promissory estoppel’ and this nomenclature is well chosen as indicating that the basis of the doctrine is not so much one of contract, with a substitute for consideration, as an application of the general principle of estoppel to certain situations.” Fried v. Fisher, 328 Pa. 497, 501, 196 A. 39, 41 (1938); see Crouse v. Cyclops Industries, 560 Pa. 394, 398, 745 A.2d 606, 610 (2000). In an effort to remedy the injustice caused by a promise that is reasonably relied upon and then broken the courts have awarded [162]*162“damages where justice requires.” Restatement (Second) of Contracts §90; Travers v. Cameron County School District, 117 Pa. Commw. 606, 613, 544 A.2d 547, 551 (1988).

The ambiguities that have arisen in the present case appear to result from two sources: (1) The confusion that arises when promissory estoppel is viewed as a substitute for consideration in contract formation and (2) the language of the Restatement which limits damages only “as justice requires.” Attempting to traverse these pitfalls it is important to keep clear that an action for promissory estoppel is not an action for breach of contract.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Rosoff v. Mountain Laurel Center for the Performing Arts
317 F. Supp. 2d 493 (S.D. New York, 2004)

Cite This Page — Counsel Stack

Bluebook (online)
57 Pa. D. & C.4th 157, 2002 Pa. Dist. & Cnty. Dec. LEXIS 124, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thompson-v-schriver-pactcompljeffer-2002.