Case Analysis and Concepts in Contractual Remedies: Promissory Estoppel
and Quasi-Contract
Promissory Estoppel
Case Example: Aceves v. U.S. Bank (2011)
Facts: Claudia Aceves, facing foreclosure, filed for bankruptcy under
Chapter 7. U.S. Bank assured her that it would work with her to modify and
reinstate her loan if she left bankruptcy proceedings. Relying on this
promise, Aceves refrained from converting to Chapter 13, which would have
allowed her to keep her home. Instead, U.S. Bank proceeded with
foreclosure without negotiation, leaving Aceves without her home.
Holding: The court allowed Aceves’s promissory estoppel claim, ruling that
her reliance on U.S. Bank’s promise was foreseeable and reasonable. The
bank’s promise to negotiate reinstatement was clear and unambiguous, and
Aceves suffered a detriment by forgoing Chapter 13 protections.
Significance: This case demonstrates how promissory estoppel can enforce
a promise when there is clear reliance by the promisee, the promisor could
reasonably foresee this reliance, and injustice would result if the promise is
not enforced.
Quasi-Contract and Unjust Enrichment
Case Example: Palese v. Delaware State Lottery Office (2006)
Facts: Palese lost his lottery ticket but retained a play slip with the winning
numbers. When he attempted to claim the prize, the Delaware Lottery
denied it, citing that the physical ticket is required by law to claim winnings.
Holding: The court dismissed Palese’s claim for unjust enrichment, ruling
that the lottery rules create an enforceable contractual obligation requiring
the ticket itself to claim winnings. As such, no quasi-contractual duty arose.
Significance: Quasi-contract cannot override explicit contract terms or
replace statutory requirements, even in cases of potential unfairness. Courts
uphold formal contractual relationships, such as ticket agreements, to
prevent parties from circumventing established rules.
Ethical Implications
Contracts and quasi-contract principles reflect ethical considerations by balancing
fairness and reliance. In promissory estoppel, a promisor is ethically bound when
the promisee suffers due to reliance on a clear, actionable promise. Quasi-contract
ensures that unjust enrichment does not occur at another’s expense, reinforcing
fairness by obligating payment for received benefits.
Part 3- Contracts, Chapter 9: Intellectual Property and Unfair Competition, Doc 4
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