Langer v. Superior Steel

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Langer v. Superior Steel
Court Pennsylvania Superior Court
Citation 161 A. 571
Date decided July 14, 1932

Facts

  • Superior Steel Corp. = "Superior" = defendant
  • "Langer" = plaintiff = a superintendent at Superior who was about to retire
  • Superior sent Langer a letter promising to pay him $100/month for the rest of his life provide that Langer didn't work for a competitor
  • After paying Langer for 4 years, Superior notified him that the pension payments would stop

Procedural History

Langer sued Superior in Pennsylvania state court for breach of contract.


Superior won.

Issues

Is a contract supported by adequate consideration if the promisee (Langer) refrains from doing something that the promisee otherwise had a right to do?

Arguments

Superior argued that its letter to Langer was a gratuitous promise.

Holding

Yes. A contract is supported by adequate consideration if the promisee refrains from doing something that the promisee otherwise had a right to do.


Furthermore, Langer could prevail under the doctrine of Promissory estoppel.

Judgment

Reversed

Reasons

Judge Baldrige: I can often be difficult to tell the difference between a gratuitous promise & an enforceable contract.

  • A promisee refrains from doing something that they otherwise had a right to do ==> adequate consideration

Rule

A Gratuitous Promise lacks consideration & don't give rise to an enforceable contract.

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