Brackenbury v. Hodgkin case brief

Brackenbury v. Hodgkin; (SJC of Maine, 1917); CB 282; Notes 37

Contrast to Fitzpatrick – Court enforces K

• Facts: D, daughter of P receives letter saying D could have use of property and would later inherit it if she comes and cares for P. In reliance upon offer D moves in to house and starts performance. Relationship acrimonious and P orders D from place. Mother claims it was unilateral K – taking care of her. Daughter says bilateral, and acceptance was them moving to Maine (this only works if the mom offered a bilateral K)

• Issue: do we want to construe what they did as agreeing to taking care of her for the rest of her life? How do we get to the fact that it is a completed and valid contract?
• Holding: where D’s begin and faithfully perform unilateral K in detrimental reliance, equitable remedy of making P involuntary trustee until her death appropriate remedy.
• Rationale: Court looks at following when assessing if equitable relief sought is appropriate: (1) unilateral K met where Ds performed as required; (2) equitable interest of Ds created by performance; (3) Ds never failed in performance.
• Commentary: Court chooses path of unilateral K b/c that way Ds allowed to get out w/out being forever bound to K. Detrimental reliance is lurking in the shadows here.