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Deli v. University of Minnesota

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Brief Fact Summary. A school's athletic director made an oral promise not to watch a videotape containing a sporting event and a sex act.  The athletic director watched the tape, and one of the individuals taped engaging in the sex act sued for breach of that promise.

Synopsis of Rule of Law. "Because promissory estoppel is a contract-based claim, to recover emotional distress damages, [a party is] required to plead and prove the existence of an independent tort."

Points of Law - Legal Principles in this Case for Law Students.

Extra-contract damages are not recoverable for breach of contract except in exceptional cases where the breach is accompanied by an independent tort.

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Facts. The Respondent, Katalin Deli (the "Respondent"), sued the Appellant, the University of Minnesota (the "Appellant"), for breach of an oral promise. The Appellant was the head coach of the Appellant's gymnastics team and her husband an assistant coach.  Appellant's athletic director orally promised not to view a videotape which included a gymnastics competition and a sexual encounter with the Appellant and her husband.  The Appellant sued the Respondent for breach of contract, unjust enrichment and promissory estoppel.

Issue. "Absent the existence of an independent tort claim, are emotional distress damages recoverable in Deli's promissory estoppel action?"

Held. The doctrine of promissory estoppel "implies a contract in law where no contract exists in fact."  Four elements must be satisfied before a promise is enforceable under this doctrine:  "(1) it is clear and definite, (2) the promissor intended to induce the promisee to rely on the promise, (3) the promisee detrimentally relied on the promise, and (4) enforcement of the promise is required to prevent an injustice."  Generally, without a relevant statutory provision to rely upon, "extra-contractual damages, such as emotional distress, are not recoverable for breach of contract." As such, "[t]he accompanying independent tort must be willful and support the extra-contractual damages in its own right." Solely a "malicious motive in breaking a contract will not convert a contract action into a tort action."  The court stresses the importance of a boundary between tort law and contract law because they each protect different interests.  The court recognized "[w]hile the inherently personal nature of the images on the videotape make this case unusual, the gravamen of Deli's promissory estoppel claim sounds in contract."  Therefore, "[b]ecause promissory estoppel is a contract-based claim, to recover emotional distress damages, Deli was required to plead and prove the existence of an independent tort."  Throughout these proceedings however, the Respondent did not do that.

Discussion. This case emphasizes the important difference between contract law and tort law and the damages applicable to each type of case. 

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