promissory estoppel doctrine in Wyoming

2010It listed the elements of promissory estoppel as: "a clear and definite agreement; proof that the party urging the doctrine acted to its detriment in reasonable reliance on the agreement; and the equities support the enforcement of the agreement." Loghry v. Unicover Corp., 927 P.2d 706, 710 (Wyo. 1996).

2002Loghry v. Unicover Corp., 927 P.2d 706, 711 (Wyo.1996). [¶ 23] Although Trabing asserts that the disclaimer in the Co Worker Handbook was not conspicuous, we do not address this claim because the evidence in this case demonstrates that Trabing routinely read the at-will provision to new employees, and she, therefore, had actual knowledge of the at-will policy whether it was conspicuous or not.

2005“The required elements of a promissory es-toppel claim are: the existence of a clear and definite agreement; proof that the party urging the doctrine acted in reasonable reliance on the agreement; and the equities support the enforcement of the agreement.” Id. [¶ 23] A valid at-will employment disclaimer, however, defeats an employee’s promissory estoppel claim.

2002Kinko’s counters that a promissory estoppel claim requires that the party invoking the doctrine have acted reasonably in justifiable reliance on the promise that was allegedly made. [¶ 22] In Worley v. Wyoming Bottling Co., Inc., 1 P.3d at 623, this court *1255 explained the remedy of promissory estoppel and outlined the required elements of a promissory estoppel claim: Promissory estoppel provides relief for an “injury arising from actions or declarations which have been acted on in good faith and which would be inequitable to permit a party to retract.” Davis v. Davis, 855 P.2d 342, 347-48 (

2015Co., 907 P.2d 1293, 1298 (Wyo. 1995) (holding that insurer’s oral promise to cover cost of surgery could not be used to alter terms of written insurance policy but may be basis to find separate enforceable promise under doctrine of promissory estoppel). [¶50] As we noted earlier in this opinion, Robert Redland has not challenged the findings underlying the district court’s application of the doctrine of promissory estoppel, but has instead confined his argument to that which we just discussed—that promissory estoppel should not be invoked because there was no basis for the court to look outsid

2015Co., 907 P.2d 1293, 1298 (Wyo.1995) (holding that insurer's oral promise to cover cost of surgery could not be used to alter terms of written insurance policy but may be basis to find separate enforceable promise under doctrine of promissory estoppel). [¶50] As we noted earlier in this opinion, Robert Redland has not challenged the findings underlying the district court's application of the doctrine of promissory estoppel, but has instead confined his argument to that which we just discussed-that promissory es-toppel should not be invoked because there was no basis for the court to look outsid

2005Thus, the elements of a promissory estoppel claim are: “(1) the existence of a clear and definite promise which the promisor should reasonably expect to induce action by the promisee; (2) proof that the promisee acted to its detriment in reasonable reliance on the promise; and (3) a finding that injustice can be avoided only if the court enforces the promise.” City of Powell v. Busboom, 2002 WY 58, ¶ 8 , 44 P.3d 63, 66 (Wyo.2002), quoting Roussalis v. Wyoming Medical Center, Inc., 4 P.3d 209, 253 (Wyo.2000).

2005Thus, the elements of a promissory estoppel claim are: “(1) the existence of a clear and definite promise which the promisor should reasonably expect to induce action by the promisee; (2) proof that the promisee acted to its detriment in reasonable reliance on the promise; and (3) a finding that injustice can be avoided only if the court enforces the promise.” City of Powell v. Busboom, 2002 WY 58, ¶ 8 , 44 P.3d 63, 66 (Wyo.2002), quoting Roussalis v. Wyoming Medical Center, Inc., 4 P.3d 209, 253 (Wyo.2000).

2005The general theory of the doctrine of promissory estoppel is: “ ‘If an unambiguous promise is made in circumstances calculated to induce reliance, and it does so, the promisee if hurt as a result can recover damages.’ ” B & W Glass, Inc. v. Weather Shield Mfg., Inc., 829 P.2d 809, 813 (Wyo.1992), quoting Goldstick v. ICM Realty, 788 F.2d 456, 462 (7th Cir.1986).

1997B & W Glass, Inc. v. Weather Shield Mfg., Inc., 829 P.2d 809, 818-19 (Wyo.1992) (citing Inter-Mountain Threading, Inc. v. Baker Hughes Tubular Services, Inc., 812 P.2d 555, 559 (Wyo.1991)); Provence v. Hilltop National Bank, 780 P.2d 990, 993 (Wyo.1989).

2002Kinko’s counters that a promissory estoppel claim requires that the party invoking the doctrine have acted reasonably in justifiable reliance on the promise that was allegedly made. [¶ 22] In Worley v. Wyoming Bottling Co., Inc., 1 P.3d at 623, this court *1255 explained the remedy of promissory estoppel and outlined the required elements of a promissory estoppel claim: Promissory estoppel provides relief for an “injury arising from actions or declarations which have been acted on in good faith and which would be inequitable to permit a party to retract.” Davis v. Davis, 855 P.2d 342, 347-48 (

2000To invoke the doctrine of promissory estoppel, there must be: “(1) a clear and definite agreement; (2) proof that the party urging the doctrine acted to its detriment in reasonable reliance on the agreement; and (3) a finding that the equities support enforcement of the agreement.” Provence v. Hilltop National Bank, 780 P.2d 990, 993 (Wyo.1989); see also Davis v. Davis, 855 P.2d 342, 348 (Wyo.1993).

2000To invoke the doctrine of promissory estoppel, there must be: “(1) a clear and definite agreement; (2) proof that the party urging the doctrine acted to its detriment in reasonable reliance on the agreement; and (3) a finding that the equities support enforcement of the agreement.” Provence v. Hilltop National Bank, 780 P.2d 990, 993 (Wyo.1989); see also Davis v. Davis, 855 P.2d 342, 348 (Wyo.1993).

1997B & W Glass, Inc. v. Weather Shield Mfg., Inc., 829 P.2d 809, 818-19 (Wyo.1992) (citing Inter-Mountain Threading, Inc. v. Baker Hughes Tubular Services, Inc., 812 P.2d 555, 559 (Wyo.1991)); Provence v. Hilltop National Bank, 780 P.2d 990, 993 (Wyo.1989).

2005Thus, the elements of a promissory estoppel claim are: “(1) the existence of a clear and definite promise which the promisor should reasonably expect to induce action by the promisee; (2) proof that the promisee acted to its detriment in reasonable reliance on the promise; and (3) a finding that injustice can be avoided only if the court enforces the promise.” City of Powell v. Busboom, 2002 WY 58, ¶ 8 , 44 P.3d 63, 66 (Wyo.2002), quoting Roussalis v. Wyoming Medical Center, Inc., 4 P.3d 209, 253 (Wyo.2000).

2005Thus, the elements of a promissory estoppel claim are: “(1) the existence of a clear and definite promise which the promisor should reasonably expect to induce action by the promisee; (2) proof that the promisee acted to its detriment in reasonable reliance on the promise; and (3) a finding that injustice can be avoided only if the court enforces the promise.” City of Powell v. Busboom, 2002 WY 58, ¶ 8 , 44 P.3d 63, 66 (Wyo.2002), quoting Roussalis v. Wyoming Medical Center, Inc., 4 P.3d 209, 253 (Wyo.2000).

1997B & W Glass, Inc. v. Weather Shield Mfg., Inc., 829 P.2d 809, 818-19 (Wyo.1992) (citing Inter-Mountain Threading, Inc. v. Baker Hughes Tubular Services, Inc., 812 P.2d 555, 559 (Wyo.1991)); Provence v. Hilltop National Bank, 780 P.2d 990, 993 (Wyo.1989).

1993In considering the doctrine of promissory estoppel as it applies to KWD’s agreement, we first of all consider whether any promises are “clear and unambiguous in their terms.” Baker Hughes, 812 P.2d at 559 .

1999About the promissory estoppel issue, two members of this Court saw the presence of genuine issues of material fact relating to the estoppel elements, id. at 870 ; three members of the Court, however, rejected the application of the promissory estoppel doctrine.

1999Id. at 871-72 .

2024See also Singer v. Lajaunie, 2014 WY 159, ¶ 28 , 339 P.3d 277, 285 (Wyo. 2014) (Because the district court’s denial of the defendant’s motion to amend his counterclaim to add fraud was, in large measure, tied to its erroneous grant of summary judgment on the defendant’s promissory estoppel claim, “the district court’s decision denying the motion to amend the counterclaim must also be reversed.”). [¶34] Independently, the district court abused its discretion by finding any amendment of the complaint would be futile.

2024See also Singer v. Lajaunie, 2014 WY 159, ¶ 28 , 339 P.3d 277, 285 (Wyo. 2014) (Because the district court’s denial of the defendant’s motion to amend his counterclaim to add fraud was, in large measure, tied to its erroneous grant of summary judgment on the defendant’s promissory estoppel claim, “the district court’s decision denying the motion to amend the counterclaim must also be reversed.”). [¶34] Independently, the district court abused its discretion by finding any amendment of the complaint would be futile.

2012Trabing [v. Kinko's, Inc., 2002 WY 171 ,] ¶22[, 57 P.3d 1248, 1255 (Wyo.2002) ].

2012Trabing [v. Kinko's, Inc., 2002 WY 171 ,] ¶22[, 57 P.3d 1248, 1255 (Wyo.2002) ].

2005See also, Parkhurst v. Boykin, 2004 WY 90, ¶21 , 94 P.3d 450, 460 (Wyo.2004). “ ‘The party who is asserting promissory estoppel is assigned the burden of establishing all of the elements of the doctrine with a standard of strict proof.’ ” Roussalis, 4 P.3d at 253 quoting B & W Glass, 829 P.2dat819. [¶23] The panel concluded Johanna had satisfied the elements of promissory estoppel.

2005See also, Parkhurst v. Boykin, 2004 WY 90, ¶21 , 94 P.3d 450, 460 (Wyo.2004). “ ‘The party who is asserting promissory estoppel is assigned the burden of establishing all of the elements of the doctrine with a standard of strict proof.’ ” Roussalis, 4 P.3d at 253 quoting B & W Glass, 829 P.2dat819. [¶23] The panel concluded Johanna had satisfied the elements of promissory estoppel.

2005The general theory of the doctrine of promissory estoppel is: “ ‘If an unambiguous promise is made in circumstances calculated to induce reliance, and it does so, the promisee if hurt as a result can recover damages.’ ” B & W Glass, Inc. v. Weather Shield Mfg., Inc., 829 P.2d 809, 813 (Wyo.1992), quoting Goldstick v. ICM Realty, 788 F.2d 456, 462 (7th Cir.1986).

2002Kinko’s counters that a promissory estoppel claim requires that the party invoking the doctrine have acted reasonably in justifiable reliance on the promise that was allegedly made. [¶ 22] In Worley v. Wyoming Bottling Co., Inc., 1 P.3d at 623, this court *1255 explained the remedy of promissory estoppel and outlined the required elements of a promissory estoppel claim: Promissory estoppel provides relief for an “injury arising from actions or declarations which have been acted on in good faith and which would be inequitable to permit a party to retract.” Davis v. Davis, 855 P.2d 342, 347-48 (

2002Tauber v. Jacobson, 293 A.2d 861, 867 (D.C.Cir.1972). [113] Furthermore, the Busbooms disregard the import of the language in the plan which unambiguously excludes self-employment-related injuries.

1996Chavez, 777 P.2d at 374 ; see Hatfield v. Bd. of County Commissioners, 52 F.3d 858 (10th Cir.1995) (applying Wyoming law).

1996Arasi v. Neema Medical Services, Inc., 407 Pa.Super. 393 , 595 A.2d 1205, 1209 (1991), appeal denied 529 Pa. 655 , 604 A.2d 247 (1992).

1996Arasi v. Neema Medical Services, Inc., 407 Pa.Super. 393 , 595 A.2d 1205, 1209 (1991), appeal denied 529 Pa. 655 , 604 A.2d 247 (1992).

1993See generally, United Self Insured Services v. Faber, 561 So.2d 1358 (Fla.App.1990) (applying doctrine of promissory estoppel).