Citation. 22 Ill.934 P.2d 1313, 12 IER Cases 1261 (Alaska 1997)
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Plaintiff Rice quit her job and relocated in reliance on a promise of employment made by Defendant, the Alaska Democratic Party. After moving to Alaska, Plaintiff was eventually informed that she did not have a job with Defendant.
Synopsis of Rule of Law.
A claim for promissory estoppel may be brought in an employment situation, even if the agreement is unenforceable under the statute of frauds.
Facts.
Plaintiff was contacted by Defendant’s potential chair regarding a position with Defendant as executive director. After becoming Defendant’s chair, the decision to hire Plaintiff was confirmed in May, 1992. The terms were to be $36,000 a year for two years with about $4,000 in fringe benefits and an additional two years if the chair was reelected. In August, 1992, Plaintiff accepted a position working on the Gore vice-presidential campaign. A month or two later, Plaintiff accepted the job with Defendant. In November, Plaintiff resigned her position with the Gore campaign, although she could have continued there indefinitely, and moved to Alaska. No written contract was entered into between Plaintiff and Defendant.
In February, 1993, the executive committee informed Defendant’s chair that Plaintiff could not be hired as executive director. Plaintiff claims that even after this meeting Defendant’s chair continued to indicate that she had the job. Later, however, Plaintiff was informed that she did not have the job.
Issue.
Did the lower court err in its awards to Plaintiff on the promissory estoppel and misrepresentation claims?
Held.
No. The lower court did not err in its awards based on either claim.
The Court holds that an oral contract falling under the statute of frauds may be enforceable under promissory estoppel. The Court finds that the jury reasonably could have found that Defendant should have expected Plaintiff to rely on the promise of employment, that Plaintiff left her job and relocated to another state in reliance on Defendant’s promise, that her reliance was both reasonable and detrimental, and that injustice would only be avoided by enforcing Defendant’s promise.
The lower court did not err in omitting “definite and substantial” from the jury instruction because the jury instructions when read as a whole required the jury to consider the definite and substantial character of Plaintiff’s actions.
With regard to the agency issues, the Court found that the evidence supported the finding of general authority, which made a finding of specific authority to hire Plaintiff unnecessary. Further, the issue of whether there was implied or apparent authority properly went to the jury. Because the question of whether there was authority to hire for a term of years rather than at will was not raised at trial, the Court considers it to have been waived.
Defendant argues that because the offer was made before the chair assumed that position; the offer cannot be the basis for the misrepresentation claim. The Court rejects that argument because the chair had a stake in offering the position to Plaintiff and did not make the offer gratuitously.
The Court also notes that the jury’s determination of what amount was necessary to avoid injustice did not result in an excessive award on the promissory estoppel claim. Further, the Court notes that the misrepresentation award was also not excessive because the total award was reduced to reflect only lost wages and benefits.
Discussion.
Because the jury had evidence to support its verdict on both claims, the Court finds that the judgments in favor of Plaintiff were not in error. The Court rejects the argument that promissory estoppel should not apply because the agreement is unenforceable under the statute of frauds. Also, the court rejects Defendant’s arguments that the damage awards were excessive.
