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Alaska Airlines, Inc. v. Stephenson

    Brief Fact Summary.

    The plaintiff was approached by the Defendant for a position at Defendant’s airline. The plaintiff relied on the offer, and gave upsomething of certain and substantial character.

    Synopsis of Rule of Law.

    The principle of promissory estoppel permits implementation of an oral employment contract only if a guarantee is made by the promisor that prompts activity of a certain and substantial character with respect to the promisee.

    Facts.

    As Arthur W. Stephenson (Plaintiff) was working for Western Airlines in California, he was drawn closer by R.W. Marshall, Chairman of Alaska Airlines, Inc. (Defendant) for a general manager position.Around then, Alaska Airlines was a little aircraft working in the Territory of Alaska bearing in mind the end goal of working to and from the United States later. Stephenson acknowledged Alaska Airlines' oral work offer, took a six-month time away from Western Airlines, and moved his family from California to Alaska. From there on, Stephenson over and over and unsuccessfully asked for a signed written employment contract from Marshall and other Alaska Airlines officials. The Alaska Airlines educated Stephenson that it would not sign any agreements until it had acquired a certificate to work to and from the United States. At this point, Stephenson's six-month time away from Western Airlines had terminated and he couldn't come back to his previous position. Subsequently, Alaska Airlines let go Stephenson. Stephenson sued Alaska Airlines in the district court for monetary damages he suffered. The district court found for Stephenson. Alaska Airlines appealed.

    Issue.

    Does the convention of promissory estoppel permit authorization of an oral employment contract if a guarantee is made by the promisor that prompts activity or avoidance of a certain and substantial character with respect to the guarantee?

    Held.

    Yes. A breach of an employment contract claim is admissible only if the agreement is in writing. Section 90 of the Restatement of the Law of Contracts states that a guarantee made by one person that initiates activity of a " definite and substantial character on the part of the promisee " is binding if unfairness can only be evaded by the implementation of the promise.

    Dissent.

    N/A

    Concurrence.

    N/A

    Discussion.

    The Statute of Frauds keeps Stephenson from winning because a breach of an employment contract claim is permissible only if the agreement is in writing.  However, in our case, Stephenson giving up his employment rights with Western Airlines fulfills the prerequisite of the Restatement that an individual gives up something of certain and substantial character.The judgment of the district court is affirmed.


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