promissory estoppel doctrine in Indiana

2023See Jarboe v. Landmark Cmty. Newspapers of Ind., Inc., 644 N.E.2d 118, 122 (Ind. 1994) (holding that the remedy for a claim of promissory estoppel “is limited to damages actually resulting from the detrimental reliance”); Hrezo v. City of Lawrenceburg, 934 N.E.2d 1221, 1231 (Ind. Ct. App. 2010) (“A successful party [in a promissory estoppel claim] is entitled to reliance damages only.”), trans. denied. 7 The trial court also found that “[e]nforcement of [AgReliant]’s promise is necessary to make the [Farmers] whole for the year 2018 or an injustice would result.” Appellant’s App. p. 28; see al

2010The doctrine of promissory estoppel provides that 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 the enforcement of the promise." Restatement (Second) of Contracts § 90(1); accord Jarboe v. Landmark Cmty. Newspapers of Ind., Inc., 644 N.E.2d 118, 121 (Ind.1994).

2025To establish that injustice can be avoided only through enforcement against a promisor, the promisee must show that the reliance injury is “(1) independent from the benefit of the bargain and the resulting incidental expenses and inconvenience; [and] (2) so substantial as to constitute an unjust and unconscionable injury.” Coca-Cola Co. v. Babyback’s Intern., Inc., 841 N.E.2d 557, 569 (Ind. 2006), disapproved of in part on other grounds by Pennington v. Mem.

2017We observed that thus, although the plaintiff quit her job, dropped out of college, and moved from Missouri to Indiana in reliance on the defendant’s promise to convey a house to her, the court reasoned such injuries merely established that the plaintiff “was inconvenienced as well as denied the benefit that [the Court of Appeals of Indiana | Memorandum Decision 82A01-1512-CC-2323 | January 31, 2017 Page 13 of 20 defendant’s] promise was intended to confer,” but not that the defendant’s “oral promise resulted in the ‘infliction of an unjust and unconscionable injury and loss.’” Id. (citing Bro

2004Weinig v. Weinig, 674 N.E.2d 991, 997 (Ind.Ct.App.1996).

2002Weinig v. Weinig, 674 N.E.2d 991, 997 (Ind.Ct.App.1996).

2017We observed that thus, although the plaintiff quit her job, dropped out of college, and moved from Missouri to Indiana in reliance on the defendant’s promise to convey a house to her, the court reasoned such injuries merely established that the plaintiff “was inconvenienced as well as denied the benefit that [the Court of Appeals of Indiana | Memorandum Decision 82A01-1512-CC-2323 | January 31, 2017 Page 13 of 20 defendant’s] promise was intended to confer,” but not that the defendant’s “oral promise resulted in the ‘infliction of an unjust and unconscionable injury and loss.’” Id. (citing Bro

2017We observed that thus, although the plaintiff quit her job, dropped out of college, and moved from Missouri to Indiana in reliance on the defendant’s promise to convey a house to her, the court reasoned such injuries merely established that the plaintiff “was inconvenienced as well as denied the benefit that [the Court of Appeals of Indiana | Memorandum Decision 82A01-1512-CC-2323 | January 31, 2017 Page 13 of 20 defendant’s] promise was intended to confer,” but not that the defendant’s “oral promise resulted in the ‘infliction of an unjust and unconscionable injury and loss.’” Id. (citing Bro

2023See Jarboe v. Landmark Cmty. Newspapers of Ind., Inc., 644 N.E.2d 118, 122 (Ind. 1994) (holding that the remedy for a claim of promissory estoppel “is limited to damages actually resulting from the detrimental reliance”); Hrezo v. City of Lawrenceburg, 934 N.E.2d 1221, 1231 (Ind. Ct. App. 2010) (“A successful party [in a promissory estoppel claim] is entitled to reliance damages only.”), trans. denied. 7 The trial court also found that “[e]nforcement of [AgReliant]’s promise is necessary to make the [Farmers] whole for the year 2018 or an injustice would result.” Appellant’s App. p. 28; see al

2020Hrezo v. City of Lawrenceburg, 934 N.E.2d 1221, 1230 (Ind. Ct. App. 2010).

2023See Jarboe v. Landmark Cmty. Newspapers of Ind., Inc., 644 N.E.2d 118, 122 (Ind. 1994) (holding that the remedy for a claim of promissory estoppel “is limited to damages actually resulting from the detrimental reliance”); Hrezo v. City of Lawrenceburg, 934 N.E.2d 1221, 1231 (Ind. Ct. App. 2010) (“A successful party [in a promissory estoppel claim] is entitled to reliance damages only.”), trans. denied. 7 The trial court also found that “[e]nforcement of [AgReliant]’s promise is necessary to make the [Farmers] whole for the year 2018 or an injustice would result.” Appellant’s App. p. 28; see al

2019As we recently explained: Court of Appeals of Indiana | Memorandum Decision 18A-PL-1421 | March 28, 2019 Page 7 of 10 “Estoppel is not generally applicable against government entities for the actions of public officials.” Biddle v. BAA Indianapolis, LLC, 860 N.E.2d 570, 581 (Ind. 2007). . . .

2012See Filter Specialists, Inc. v. Brooks, 906 N.E.2d 835, 838 (Ind. 2009).

2012See Filter Specialists, Inc. v. Brooks, 906 N.E.2d 835, 838 (Ind.2009).

2007Co., 555 N.E.2d 844, 847 (Ind.Ct.App.1990) (quoting Woodall v. Citizens Banking Co., 507 N.E.2d 999, 1000 (Ind.Ct.App. 1987)).

1990The corporations correctly note that "the doctrine of promissory estoppel applies where there is a promise upon which the promisor could reasonably expect to induce action or forbearance of a definite and substantial character which does in fact induce such action or forbearance and injustice can only be avoided by enforcement of the promise." Appellants' Brief at 13; see Woodall v. Citizens Banking Co. (1987), Ind.App., 507 N.E.2d 999, 1000 , trans. denied; Security Bank & Trust Co. v. Bogard (1986), Ind. App., 494 N.E.2d 965, 968 ; Tipton County Farm Bureau Co-op v. Hoover (1985), Ind. App.,

2000Further, “Indiana permits the enforcement of oral promises which are within the Statute of Frauds where such promises would otherwise be enforceable under the doctrine of promissory estoppel.” Tipton County Farm Bureau Co-op., Ass’n, Inc. v. Hoover, 475 N.E.2d 38, 41 (Ind.Ct.App.1985), trans. denied. 4 .

1990The corporations correctly note that "the doctrine of promissory estoppel applies where there is a promise upon which the promisor could reasonably expect to induce action or forbearance of a definite and substantial character which does in fact induce such action or forbearance and injustice can only be avoided by enforcement of the promise." Appellants' Brief at 13; see Woodall v. Citizens Banking Co. (1987), Ind.App., 507 N.E.2d 999, 1000 , trans. denied; Security Bank & Trust Co. v. Bogard (1986), Ind. App., 494 N.E.2d 965, 968 ; Tipton County Farm Bureau Co-op v. Hoover (1985), Ind. App.,

2020“Third, this Court has recognized that an employee may invoke the doctrine of promissory estoppel.” Id. (citing Orr, 689 N.E.2d at 718 ).

2020“Third, this Court has recognized that an employee may invoke the doctrine of promissory estoppel.” Id. (citing Orr, 689 N.E.2d at 718 ).

2025In Farm Bureau, Robert McCracken and Terry Bealmear were involved in an automobile accident. 765 N.E.2d at 653 .

2002Farm Bureau v. Allstate, 765 N.E.2d 651, 657-58 (Ind.Ct.App.2002).

2020As the Huber panel held, even when oral agreements fall within the Statute of Frauds, they may still be enforced under the doctrine of promissory estoppel. 33 N.E.3d at 1123 .

2015Huber v. Hamilton, 33 N.E.3d 1116, 1124 (Ind. Ct. App. 2015).

2019See Harris, 49 N.E.3d at 636 (affirming denial of Harris' wrongful termination claim on summary judgment because "the Handbook did not constitute a valid unilateral contract; and [ ] an exception to the employment-at-will doctrine did not apply to Harris"), trans. denied. [32] Accordingly, Defendants established that there were no genuine issues of material fact and that they were entitled to judgment as a matter of law on the issues of breach of contract, promissory estoppel, and wrongful termination.

2018Relying on the promissory estoppel doctrine, Neff must plead "the doctrine with particularity, demonstrating that the employer made a promise to the employee, the employee relied on the promise to his detriment, and the promise otherwise fits within the Restatement test for promissory estoppel." Id. at 644 .

2023Greives v. Greenwood, 550 N.E.2d 334, 338 (Ind. Ct. App. 1990) (“Damages for loss of reputation are only available in actions for libel, slander, abuse of process, malicious prosecution and third-party contract interference.”).

2015Our supreme court has recognized that an employee may invoke the doctrine of promissory estoppel by “pleading the doctrine with particularity, demonstrating that the employer made a promise to the employee, the employee relied on the promise to his detriment, and the promise otherwise fits within the Restatement test for promissory estoppel.” Peru School Corp., 969 N.E.2d at 133 -34 (citing Baker v. Tremco, Inc., 917 N.E.2d 660, 654 (Ind.2009)).

2015Our supreme court has recognized that an employee may invoke the doctrine of promissory estoppel by “pleading the doctrine with particularity, demonstrating that the employer made a promise to the employee, the employee relied on the promise to his detriment, and the promise otherwise fits within the Restatement test for promissory estoppel.” Peru School Corp., 969 N.E.2d at 133 -34 (citing Baker v. Tremco, Inc., 917 N.E.2d 660, 654 (Ind.2009)).

2012Co., 761 N.W.2d 151, 166 (Mich. Ct. App. 2008).

2011“A claim for unjust enrichment ‘is a legal fiction invented by the common law courts in order to permit a recovery ... where the circumstances are such that under the law of natural and immutable justice there should be a recovery....’” Zoeller, 904 N.E.2d at 220 (quoting Bayh v. Sonnenburg, 573 N.E.2d 398, 408 (Ind.1991), ce rt. denied (1992)).

2008Promissory estoppel or “quasi-contractual remedies permit recovery where no contract in fact exists.” Bailey v. Manors Group, 642 N.E.2d 249, 253 (Ind.Ct.App.1994), trans. denied.