Blinn v. Beatrice Hospital

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Blinn v. Beatrice Hospital
Court Nebraska Supreme Court
Citation 708 N.W.2d 235
Date decided January 6, 2006

Facts

Mr. Blinn was an at-will employee; he was 67 years old. His employer was Beatrice Community Hospital and Health Center, Inc. ("Beatrice").

In June 2002, Blinn received a job offer from another hospital in Kansas. However, after obtaining assurances from Beatrice that his job with Beatrice was secure, Blinn decide the job offer from the Kansas hospital.

Nontheless, in early 2003, Beatrice asked Blinn to resign from his position. Blinn refused to resign; so, he was terminated.

Procedural History

Blinn sued Beatrice in state district court for wrongful discharge. Blinn lost.

Blinn won in the Nebraska court of appeals.

Issues

Can an at-will employee maintain an action for promissory estoppel?

May a party maintain an action for promissory estoppel based on a promise that's insufficiently definite to form a binding contract?

Arguments

Blinn: Beatrice's oral representation induced him to forgo another employment offer.

Holding

Yes. A party [Blinn] may maintain an action for promissory estoppel based on a promise that's insufficiently definite to form a binding contract if the promisee's reliance on the promise is reasonable & foreseeable.

Judgment

Reversed & affirmed in part the decision of the court of appeals.

Reasons

Justice Gerrard: The court of appeals erred in reversing the trial court's holding that no genuine issues of material fact existed on Blinn's claim for breach of contract.

Rule

In many states, the definiteness requirement for contracts doesn't apply to claims for promissory estoppel.

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