Tuesday, December 3, 2013

Alden v. Vernon Presley case brief

Alden v. Vernon Presley case brief summary
637 S.W.2d 862 (1982)

Defendant promisor's estate challenged the Court of Appeals (Tennessee) order, reversing a judgment in its favor in plaintiff promisee's action to enforce a promise to pay mortgage indebtedness. It alleged that plaintiff failed to establish detrimental reliance requisite to a claim of promissory estoppel.

Plaintiff promisee filed an action against defendant promisor's estate, seeking to enforce a promise to pay a home mortgage obligation in connection with plaintiff's divorce settlement. The appellate court reversed a judgment in favor of defendant on the grounds of promissory estoppel and defendant sought review.


  • The court reversed, ruling that plaintiff had failed to prove the detrimental reliance and resultant loss, which were necessary to promissory estoppel. 
  • Plaintiff showed that decedent's promise had induced her to incur a $ 39,587 mortgage as part of a divorce settlement agreement, but the agreement was not binding on her or her husband until approved by the divorce court. 
  • Defendant denied liability for decedent's gratuitous promise to pay the mortgage before the agreement received court approval. 
  • This removed the element of detrimental reliance from the case. 
  • Thus, plaintiff's reliance on the promise after defendant denied liability was not reasonably justified and any loss incurred did not result from her justifiable reliance.

The court reversed the judgment of the appellate court and ruled that plaintiff promisee had failed to establish the detrimental reliance and resultant loss necessary for promissory estoppel in her action to enforce a promise against defendant promisor's estate. After defendant denied liability for the decedent's promise, plaintiff's continued reliance on the promise was not reasonably justified and her loss was not due to justifiable reliance.

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