Dargo v. Clear Channel Communications, Incorporated

Brief Fact Summary.

Plaintiff moved from Chicago to Minneapolis, signing a one-year lease, after accepting a job offer from Defendant, which promised a higher salary and a two-year employment contract. Plaintiff never received the promised two-year employment contract, and she was fired shortly after beginning her new job. Plaintiff sued Defendant, among other allegation, for promissory estoppel. Defendant moved to dismiss Plaintiff’s complaint.

Synopsis of Rule of Law.

A promissory estoppel claim is not valid if supported by consideration.

Facts.

Kassie Dargo (Plaintiff) worked in Chicago, until Clear Channel Communications (Defendant) recruited her to work for it in Minneapolis. Defendant promised Plaintiff a higher salary and a two-year employment contract. Plaintiff accepted, quit her job in Chicago, moved to Minneapolis, and signed a one-year lease for housing. Plaintiff never received the promised two-year employment contract, and she was fired shortly after beginning her new job.

Issue.

Whether a promissory estoppel claim supported by consideration is valid.

Held.

No. Plaintiff’s promissory estoppel claim is denied. A promissory estoppel claim is not valid if supported by consideration.

Discussion.

The elements of a valid promissory estoppel claim are 1) an unambiguous promise; 2) which induced reliance; 3) that was foreseeable; and 4) to the person’s detriment. Promissory estoppel is applicable when the contract would be valid but for want of consideration. When consideration is present, promissory estoppel is inappropriate. Consideration exists when a party suffers a determent in exchange for something of value. Plaintiff provided consideration by relocating and assuming a lease obligation. Promissory estoppel is, therefore, not appropriate in this case.