Following a workplace injury, longtime employee and plaintiff I. G. Katz was offered a pension in exchange for retirement by defendant Dare, who would have fired Katz if he had not accepted it. Three years later, when Katz was 70 years old, Dare stopped making payments and claimed Katz was capable of working. Katz sued under promissory estoppel.
Rules of law
There are three elements that invoke Promissory Estoppel: promise, detrimental reliance, and injustice which compels enforcement.
Defendant argued that because plaintiff would have been fired if he had not voluntarily retired, the elements of Promissory Estoppel had not been met. Defendant argued that the pension from Dare did not require Katz to do anything and thus there was no detrimental reliance. Plaintiff argued that he had relied on the promise to his detriment by voluntarily quitting.
The court held that the alternative of firing was immaterial, as the defendant had negotiated a voluntary termination for thirteen months, and plaintiff had in fact relied upon the promise in voluntarily quitting.