Case 9-3 Bouton v. Byers

Reasoning

A promissory estoppel is an equitable doctrine designed to promote some measure of basic fairness when one party makes a representation or promise in a manner reasonably inducing another party to undertake some obligation or to incur some detriment as a result. The Kansas Supreme Court has recognized promissory estoppel to be applicable when: 1) a promisor reasonably expects a promisee to act in reliance on a promise, 2) the promisee, in turn, reasonably so acts, 3) a court's refusal to enforce the promise would countenance a substantial injustice. Bouton left a lucrative job after being promised in March 2015 by Byers that she would inherit the land. Once she left the tenure-track job, it was lost to her. The income that she earned on the ranch was no where near what she earned at the school, which was very detrimental to her. Earlier her father had voiced concern that leaving the school and working full-time on the ranch was not a good idea. This indicates that he not only expected her to act on the promise but that he intended her to do so. The courts will enforce a promise that the promisor should reasonably expect to induce detrimental reliance by the promise if the promise takes such action and justice requires

Plaintiff

Bouton

Defendant

Byers

Summary

Byers convinced Bouton to give up her high paying job to come work for Byers (her father) on his ranch under the stipulation that Bouton would receive the ranch as inheritance. Shortly after, Byers sold the land for 1.2 million. Bouton will inherit nothing. Bouton relied on that contract and inheritance for her well being, and is unable to go back to her job.

Where are we?

Court of Appeals of Kansas, 2014

Issue

Is a promise enforcable? Promissory estoppe

Decision

Reversed, in favor of Bouton if she can prove promissory estoppel in lower courts she'll get the money.

Where are we?

Supreme Court of Idaho 2002