Alden v. Vernon Presley

Brief Fact Summary.

Elvis promised his girlfriend that he would pay the mortgage on her home. Relying on this promise, his girlfriend got divorced from her husband. Elvis died without paying the debt on her home.

Synopsis of Rule of Law.

Under promissory estoppel, a promise is not enforceable unless one’s reliance is reasonable and detrimental.

Facts.

Jo Laverne Alden (Plaintiff), the mother of Ginger Alden, the former girlfriend of late Elvis Presley, brought suit against Elvis Presley’s estate (Defendant) to enforce a promises made by Elvis before he died. Elvis had promised to pay for Alden’s divorce, to buy the husband’s equity in the home, and to pay off the leftover debt on the home. Alden filed for divorce from her husband because of Elvis’ promises. After fulfilling the other promises, Elvis died before he could pay off the leftover debt on the home. Defendant refused to assume responsibility for the debt. To settle with her husband, Alden assumed responsibility for the debt on the home as well as responsibility for the mortgage. However, the agreement was never submitted to the court. Alden later refused to honor the agreement with her husband. After Plaintiff filed suit, the trial court held in favor of Defendant. The trial court held that the promise to pay the debt was simply a gift that was not given. As a result, Alden appealed to the appellate court, which affirmed the trial court holding that there was no gift and reversed the trial court’s ruling with respect to promissory estoppel. The appellate court held that Alden had endured sufficient forbearance in reliance on Elvis’ promise. Defendant subsequently appealed to the Supreme Court of Tennessee.

Issue.

For promissory estoppel to apply, can a promise be enforceable against a promisor when the reliance on the promise is not reasonable and detrimental to the promisee?

Held.

No. Promissory estoppel applies when the promisee reasonably relies on the promise to his or her detriment. In this case, Alden assumed responsibility for the debt on the home under the settlement agreement with her husband based on Elvis’ promise. Since she refused to honor the agreement, she has not suffered any detriment as a result of her reliance on Elvis’ promise. Thus, Alden’s reliance on Elvis’ promise is not reasonable. The Supreme Court of Tennessee reversed the holding of the appellate court, and dismissed Plaintiff’s case.

Discussion.

A contract is created and binding under promissory estoppel when the promisor expects to and does cause action or forbearance on the part of the promisee that is definite and substantial; such a promise will be enforced if injustice can be avoided only by enforcing the promise. Any reliance on the promisor’s promise must have been not only reasonable but also detrimental to the promisee.