Already have an account? Sign in instead.
You stay signed in for 30 days on this browser.
Continue with Google Continue with MicrosoftNo account yet? Create a free one.
We sent a six-digit code.
It expires in ten minutes, works once, and only in this browser. Five wrong tries void it. Send another code.
Your account is live and the Cloudflare checks are off for this browser.
29 Washington opinions name it 2 courts 1962–2025 3 in the last five years
The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Bulman v. Safeway, Inc.green1 sentence2002Note, the basis for Bulman's justifiable reliance element appears to be the standard promissory estoppel analysis as found in Klirike v. Famous Recipe Fried Chicken, Inc., 94 Wash.2d 255 , 259 n. 2, 616 P.2d 644 (1980). [26] Thompson, 102 Wash.2d at 230-31 , 685 P.2d 1081 . [27] Swanson, 118 Wash.2d at 532 , 826 P.2d 664 . [28] Swanson, 118 Wash.2d at 530-31 , 826 P.2d 664 . [29] Swanson, 118 Wash.2d at 528, 534 , 826 P.2d 664 ; see also Bulman, 144 Wash.2d at 350 , 27 P.3d 1172 . | 1 | 1 |
Bulman v. Safeway, Inc.green1 sentence2002Note, the basis for Bulman's justifiable reliance element appears to be the standard promissory estoppel analysis as found in Klirike v. Famous Recipe Fried Chicken, Inc., 94 Wash.2d 255 , 259 n. 2, 616 P.2d 644 (1980). [26] Thompson, 102 Wash.2d at 230-31 , 685 P.2d 1081 . [27] Swanson, 118 Wash.2d at 532 , 826 P.2d 664 . [28] Swanson, 118 Wash.2d at 530-31 , 826 P.2d 664 . [29] Swanson, 118 Wash.2d at 528, 534 , 826 P.2d 664 ; see also Bulman, 144 Wash.2d at 350 , 27 P.3d 1172 . | 1 | 1 |
Swanson v. Liquid Air Corporationgreen2 sentences2002Note, the basis for Bulman's justifiable reliance element appears to be the standard promissory estoppel analysis as found in Klirike v. Famous Recipe Fried Chicken, Inc., 94 Wash.2d 255 , 259 n. 2, 616 P.2d 644 (1980). [26] Thompson, 102 Wash.2d at 230-31 , 685 P.2d 1081 . [27] Swanson, 118 Wash.2d at 532 , 826 P.2d 664 . [28] Swanson, 118 Wash.2d at 530-31 , 826 P.2d 664 . [29] Swanson, 118 Wash.2d at 528, 534 , 826 P.2d 664 ; see also Bulman, 144 Wash.2d at 350 , 27 P.3d 1172 . 2002Note, the basis for Bulman's justifiable reliance element appears to be the standard promissory estoppel analysis as found in Klirike v. Famous Recipe Fried Chicken, Inc., 94 Wash.2d 255 , 259 n. 2, 616 P.2d 644 (1980). [26] Thompson, 102 Wash.2d at 230-31 , 685 P.2d 1081 . [27] Swanson, 118 Wash.2d at 532 , 826 P.2d 664 . [28] Swanson, 118 Wash.2d at 530-31 , 826 P.2d 664 . [29] Swanson, 118 Wash.2d at 528, 534 , 826 P.2d 664 ; see also Bulman, 144 Wash.2d at 350 , 27 P.3d 1172 . | 1 | 1 |
In Re Tveekrem's Estategreen2 sentences1989See In re Estate of Tveekrem, 169 Wash. 468 , 14 P.2d 3 (1932). 3 The unsigned notes fulfill no requirements of the statute and prove nothing whatsoever. 4 The doctrine of promissory estoppel, injected into the case sua sponte by the trial judge, is inapplicable. 1989See In re Estate of Tveekrem, 169 Wash. 468 , 14 P.2d 3 (1932). 3 The unsigned notes fulfill no requirements of the statute and prove nothing whatsoever. 4 The doctrine of promissory estoppel, injected into the case sua sponte by the trial judge, is inapplicable. | 1 | 1 |
Chrysler Corporation v. Quimbygreen2 sentences1988Chrysler Corp. v. Quimby, 51 Del. 264, 283-84 , 144 A.2d 123, 885 (1958). 1988Chrysler Corp. v. Quimby, 51 Del. 264, 283-84 , 144 A.2d 123, 885 (1958). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Klinke v. Famous Recipe Fried Chicken, Inc.
green
2 sentences2005There are five recognized elements of a promissory estoppel claim: “(1) a promise, (2) that promisor should reasonably expect to cause the promisee to change his position, and (3) actually causes the promisee to change his position, (4) justifiably relying on the promise, (5) in such a manner that injustice can be avoided only by enforcement of the promise.” Id. 2005There are five recognized elements of a promissory estoppel claim: "(1) a promise, (2) that promisor should reasonably expect to cause the promisee to change his position, and (3) actually causes the promisee to change his position, (4) justifiably relying on the promise, (5) in such a manner that injustice can be avoided only by enforcement of the promise." Id. | 10 | 1993–2019 |
Havens v. C & D PLASTICS, INC.
green
2 sentences2019Havens v. C & D Plastics, Inc., 124 Wn.2d 158, 173 , 876 P.2d 435 (1994). 2019Havens v. C & D Plastics, Inc., 124 Wn.2d 158, 173 , 876 P.2d 435 (1994). | 3 | 1997–2019 |
Henschel v. Oregon Fire & Marine Insurance
green
2 sentences2006Ed. 2d 365 (1987)). ¶13 The equitable nature of a promissory estoppel claim is illustrated in Henschel v. Oregon Fire & Marine Insurance Co., 4 Wash. 476 , 30 P. 735 , 31 P. 332 (1892). 2006Ed. 2d 365 (1987)). ¶13 The equitable nature of a promissory estoppel claim is illustrated in Henschel v. Oregon Fire & Marine Insurance Co., 4 Wash. 476 , 30 P. 735 , 31 P. 332 (1892). | 2 | 2006–2006 |
Thompson v. St. Regis Paper Company
green
2 sentences2002Note, the basis for Bulman's justifiable reliance element appears to be the standard promissory estoppel analysis as found in Klirike v. Famous Recipe Fried Chicken, Inc., 94 Wash.2d 255 , 259 n. 2, 616 P.2d 644 (1980). [26] Thompson, 102 Wash.2d at 230-31 , 685 P.2d 1081 . [27] Swanson, 118 Wash.2d at 532 , 826 P.2d 664 . [28] Swanson, 118 Wash.2d at 530-31 , 826 P.2d 664 . [29] Swanson, 118 Wash.2d at 528, 534 , 826 P.2d 664 ; see also Bulman, 144 Wash.2d at 350 , 27 P.3d 1172 . 2002Note, the basis for Bulman's justifiable reliance element appears to be the standard promissory estoppel analysis as found in Klirike v. Famous Recipe Fried Chicken, Inc., 94 Wash.2d 255 , 259 n. 2, 616 P.2d 644 (1980). [26] Thompson, 102 Wash.2d at 230-31 , 685 P.2d 1081 . [27] Swanson, 118 Wash.2d at 532 , 826 P.2d 664 . [28] Swanson, 118 Wash.2d at 530-31 , 826 P.2d 664 . [29] Swanson, 118 Wash.2d at 528, 534 , 826 P.2d 664 ; see also Bulman, 144 Wash.2d at 350 , 27 P.3d 1172 . | 2 | 2002–2002 |
Drennan v. Star Paving Co.
green
2 sentences1986Drennan v. Star Paving Co., 51 Cal. 2d 409 , 333 P.2d 757 (1958). 1986Drennan v. Star Paving Co., 51 Cal. 2d 409 , 333 P.2d 757 (1958). | 2 | 1978–1986 |
Tradewell Group, Inc. v. Mavis
green
1 sentence2025Id. | 1 | 2025–2025 |
Stewart v. Cendant Mobility Services Corp.
green
2 sentences2025Corp., 267 Conn. 96, 105 , 837 A.2d 736 (2003) (alterations in original) (quoting 3 A. Corbin, Contracts § 8.9, p. 29 (Rev. 2025Corp., 267 Conn. 96, 105 , 837 A.2d 736 (2003) (alterations in original) (quoting 3 A. Corbin, Contracts § 8.9, p. 29 (Rev. | 1 | 2025–2025 |
Spectrum Glass Co. v. Public Utility District No. 1
green
1 sentence2021Similarly, “the doctrine of promissory estoppel does not apply where a contract governs.” Spectrum Glass Co., 129 Wn. | 1 | 2021–2021 |
Hathaway v. Yakima Water, Light & Power Co.
green
1 sentence2019Because the undisputed facts show that Hoy obtained a revocable license, he may not invoke the promissory estoppel doctrine. ~ Hathaway, 14 Wn. at 472 ; Showalter, 118 Wn. | 1 | 2019–2019 |
Showalter v. City of Cheney
green
1 sentence2019Because the undisputed facts show that Hoy obtained a revocable license, he may not invoke the promissory estoppel doctrine. ~ Hathaway, 14 Wn. at 472 ; Showalter, 118 Wn. | 1 | 2019–2019 |
Belli v. Shaw
green
1 sentence2017We assume for purposes of this decision that Karstetter was an employee of the Guild. 13 Barr, 124 Wn.2d at 328 ; Belli, 98 Wn.2d at 577 ; Kimball, 64 Wn.2d at 257 . -8- No. 75671-1-1 / 9 Karstetter relies on Corey v. Pierce County." There, a Pierce County deputy prosecutor made a promissory estoppel claim based on a representation that her employment contract contained a "just cause" provision.15 But our Corey decision does not help Karstetter because we were not asked to consider and did not decide whether the alleged contract violated public policy.16 Karstetter also relies on Chism v. Tri- | 1 | 2017–2017 |
Barr v. Day
green
1 sentence2017We assume for purposes of this decision that Karstetter was an employee of the Guild. 13 Barr, 124 Wn.2d at 328 ; Belli, 98 Wn.2d at 577 ; Kimball, 64 Wn.2d at 257 . -8- No. 75671-1-1 / 9 Karstetter relies on Corey v. Pierce County." There, a Pierce County deputy prosecutor made a promissory estoppel claim based on a representation that her employment contract contained a "just cause" provision.15 But our Corey decision does not help Karstetter because we were not asked to consider and did not decide whether the alleged contract violated public policy.16 Karstetter also relies on Chism v. Tri- | 1 | 2017–2017 |
Kimball v. Public Utility District No. 1
green
1 sentence2017We assume for purposes of this decision that Karstetter was an employee of the Guild. 13 Barr, 124 Wn.2d at 328 ; Belli, 98 Wn.2d at 577 ; Kimball, 64 Wn.2d at 257 . -8- No. 75671-1-1 / 9 Karstetter relies on Corey v. Pierce County." There, a Pierce County deputy prosecutor made a promissory estoppel claim based on a representation that her employment contract contained a "just cause" provision.15 But our Corey decision does not help Karstetter because we were not asked to consider and did not decide whether the alleged contract violated public policy.16 Karstetter also relies on Chism v. Tri- | 1 | 2017–2017 |
Ash v. Department of Labor & Industries
neutral
1 sentence2015App. 559, 566-67 , 294 P.3d 834 (2013). -18- NO. 71114-8-1/19 But a party seeking damages based on an estoppel claim must assert a promissory estoppel claim, not a claim for equitable estoppel.40 While at least one Washington case recasts a claim for equitable estoppel as one for promissory estoppel,41 we decline to do so here. | 1 | 2015–2015 |
Sofie v. Fibreboard Corp.
green
1 sentence2006Sofie v. Fibreboard Corp., 112 Wash.2d 636, 649 , 771 P.2d 711 (1989) (citing Tull v. United States, 481 U.S. 412 , 107 S.Ct. 1831 , 95 L.Ed.2d 365 , (1987)). ¶ 13 The equitable nature of a promissory estoppel claim is illustrated in Henschel v. *982 Oregon Fire & Marine Ins. | 1 | 2006–2006 |
Tull v. United States
green
2 sentences2006Sofie v. Fibreboard Corp., 112 Wash.2d 636, 649 , 771 P.2d 711 (1989) (citing Tull v. United States, 481 U.S. 412 , 107 S.Ct. 1831 , 95 L.Ed.2d 365 , (1987)). ¶ 13 The equitable nature of a promissory estoppel claim is illustrated in Henschel v. *982 Oregon Fire & Marine Ins. 2006Sofie v. Fibreboard Corp., 112 Wash.2d 636, 649 , 771 P.2d 711 (1989) (citing Tull v. United States, 481 U.S. 412 , 107 S.Ct. 1831 , 95 L.Ed.2d 365 , (1987)). ¶ 13 The equitable nature of a promissory estoppel claim is illustrated in Henschel v. *982 Oregon Fire & Marine Ins. | 1 | 2006–2006 |
Shaw v. Housing Authority
green
1 sentence1998App. 755, 760-61 , 880 P.2d 1006 (1994) (likening the cause of action based upon promises of specific treatment in specific situations to the equitable doctrine of promissory estoppel). | 1 | 1998–1998 |
McDonnell Douglas Corp. v. Green
green
2 sentences1990Green and Shields, JJ., concur. 1 In opposing summary judgment, this latter cause of action gave way to a promissory estoppel claim. 2 RCW 49.60.180 provides: "It is an unfair practice for any employer: "(2) To discharge or har any person from employment because of age, sex, marital status, race, creed, color, national origin . . .”. 3 These elements are an adaptation of the elements set out in McDonnell Douglas Corp. v. Green, 411 U.S. 792 , 36 L. 1990Green and Shields, JJ., concur. 1 In opposing summary judgment, this latter cause of action gave way to a promissory estoppel claim. 2 RCW 49.60.180 provides: "It is an unfair practice for any employer: "(2) To discharge or har any person from employment because of age, sex, marital status, race, creed, color, national origin . . .”. 3 These elements are an adaptation of the elements set out in McDonnell Douglas Corp. v. Green, 411 U.S. 792 , 36 L. | 1 | 1990–1990 |
Chrysler Corp. v. Quimby
green
2 sentences1988Chrysler Corp. v. Quimby, 51 Del. 264, 283-84 , 144 A.2d 123, 885 (1958). 1988Chrysler Corp. v. Quimby, 51 Del. 264, 283-84 , 144 A.2d 123, 885 (1958). | 1 | 1988–1988 |
Corbit v. J. I. Case Co.
green
2 sentences1979Case Co., 70 Wn.2d 522, 538-39 , 424 P.2d 290 (1967); Gorge Lumber Co. v. *609 Brazier Lumber Co., 6 Wn. 1979Case Co., 70 Wn.2d 522, 538-39 , 424 P.2d 290 (1967); Gorge Lumber Co. v. *609 Brazier Lumber Co., 6 Wn. | 1 | 1979–1979 |
Gorge Lumber Co. v. Brazier Lumber Co.
green
1 sentence1979Case Co., 70 Wn.2d 522, 538-39 , 424 P.2d 290 (1967); Gorge Lumber Co. v. *609 Brazier Lumber Co., 6 Wn. | 1 | 1979–1979 |
Hellbaum v. Burwell & Morford
green
1 sentence1972As noted in a footnote by the court in Hellbaum v. Burwell & Morford, 1 Wn. | 1 | 1972–1972 |
East Providence Credit Union v. Geremia
green
1 sentence1969Graddon v. Knight, supra; East Providence Credit Union v. Geremia, supra; Henderson, Promissory Estoppel and Traditional Contract Doctrine, 78 Yale L.J. 343 (1969). 2 The doctrine of promissory estoppel based on Restatement of Contracts § 90 (1932) has long been recognized in this state. *701 Central Heat Inc. v. Daily Olympian Inc., 74 Wn.2d 126 , 443 P.2d 544 (1968); Corbit v. J. | 1 | 1969–1969 |
Central Heat, Inc. v. Daily Olympian, Inc.
green
2 sentences1969Graddon v. Knight, supra; East Providence Credit Union v. Geremia, supra; Henderson, Promissory Estoppel and Traditional Contract Doctrine, 78 Yale L.J. 343 (1969). 2 The doctrine of promissory estoppel based on Restatement of Contracts § 90 (1932) has long been recognized in this state. *701 Central Heat Inc. v. Daily Olympian Inc., 74 Wn.2d 126 , 443 P.2d 544 (1968); Corbit v. J. 1969Graddon v. Knight, supra; East Providence Credit Union v. Geremia, supra; Henderson, Promissory Estoppel and Traditional Contract Doctrine, 78 Yale L.J. 343 (1969). 2 The doctrine of promissory estoppel based on Restatement of Contracts § 90 (1932) has long been recognized in this state. *701 Central Heat Inc. v. Daily Olympian Inc., 74 Wn.2d 126 , 443 P.2d 544 (1968); Corbit v. J. | 1 | 1969–1969 |
Hill v. Corbett
neutral
1 sentence1962In Hill v. Corbett, 33 Wn. (2d) 219, 204 P. (2d) 845 (1949), the essential elements of promissory estoppel are set out as follows: “ . . . (1) a promise which (2) the promisor should reasonably expect to cause the promisee to change his position and (3) which does cause the promisee to change his position (4) justifiably relying upon the promise, in such a manner that (5) injustice can be avoided only by enforcement of the promise.” Appellants designate the fourth element as the “crucial issue”: Did the evidence establish that S. A. Weitman was justified in relying upon the promises of Owen? | 1 | 1962–1962 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.