Wheeler
v. White
Supreme Court of
398 S.W.2d 93
Facts: Wheeler sued White because
White allegedly breached a contract to finance construction on Wheeler’s
land. In reliance on this contract,
Wheeler knocked down some buildings on his land, after which the financing
never came through. Wheeler said if the contract
was uncertain, White should be barred from saying the contract was uncertain
because of his actions which reasonably induced Wheeler to knock down the
buildings. White said the contract was
indeed too uncertain and that the doctrine of estoppel couldn’t create a ground
for Wheeler to recover. The trial court dismissed
Wheeler’s case and Wheeler appealed.
Issue: Does the doctrine of promissory
estoppel bar White from claiming that the contract is void for vagueness since
he induced Wheeler’s reliance?
Rule: When a party acts to his
detriment in reasonable reliance on an otherwise unenforceable promise and is
injured, that party may have a claim for breach.
Analysis:
The court
sort of sees this as a classic promissory estoppel case. If Wheeler can prove the facts as he alleges
them, then he has a good claim against White.
White was trying to influence Wheeler’s conduct by promising to get him
financing. White actually did succeed in
influencing Wheeler’s conduct. But then
White backed out. The contract is no
good, but promissory estoppel has the power to make stuff enforceable that is usually
not enforceable.
Conclusion: The dismissal is reversed
and the case is remanded for trial.
Questions
1. It seems that
the difference is in the side that brought the action. If Ball-Co. had brought suit against Empro on a promissory estoppel theory, I think they could
have succeeded if Empro had told them outside the
context of the letter that they were definitely going to buy Ball-Co. and thus
it would not be necessary for them to negotiate with anyone else. In Wheeler, the plaintiff relied on
the defendant.