Tuesday, December 3, 2013

Dyer v. National By-Products Inc. case brief

Dyer v. National By-Products Inc. case brief summary
380 N.W.2d 732 (1986)


CASE SYNOPSIS
Appellant employee sought review of an order of the Iowa District Court for Polk County, which granted appellee employer's motion for summary judgment in the employee's action for breach of an oral contract.

CASE FACTS
The employee was injured in a work-related accident and after returning to work was laid off. The employee filed an action against the employer alleging a breach of an oral contract. The employee claimed that his forbearance in litigating a personal injury claim that he in good faith believed he had was made in exchange for a promise from the employer that he would have lifetime employment. The employer filed a motion for summary judgment claiming that there was no genuine factual issue and the trial court granted the motion.

DISCUSSION

  • On appeal, the court reversed the decision and held that forbearance of a claim that proved to be invalid was sufficient consideration if the forbearing party believed in good faith that the claim was valid. 
  • The court held that summary judgment was improper because a question of material fact existed as to whether the employee's forbearance was made in good faith. 
  • The court remanded the case for determination of that issue.

CONCLUSION
The court reversed the grant of summary judgment to the employer in the employee's action for breach of an oral contract and remanded the case for determination of whether the employee's forbearance to assert his personal injury claim was in good faith.

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