Wednesday, December 25, 2013

Schott v. Westinghouse Electric Corporation case brief

Schott v. Westinghouse Electric Corporation case brief summary
259 A.2d 443 (1969)

CASE SYNOPSIS
Appellant employee sought review of an order of the Court of Common Pleas of Allegheny County (Pennsylvania), which dismissed its complaint for breach of contract and unjust enrichment against appellee employer.

CASE FACTS
Appellee, an electric corporation, developed a formalized suggestion program under which its employees were invited to submit to the company any suggestions they might have had for increasing production and reducing costs. Cash awards were offered for each suggestion adopted. Appellant submitted a suggestion, which appellee rejected. However, appellant alleged that appellee actually adopted and utilized the recommendations advanced by the suggestion. Appellee refused to make an award to appellant, asserting that the action taken was independent of his rejection. Appellant filed an amended complaint alleging breach of contract and unjust enrichment. The lower court sustained appellee's objections and dismissed the amended complaint.

DISCUSSION

  • On appeal, the court found that appellant could not have recovered under a contract theory, but could have recovered under the unjust enrichment cause of action. 
  • The court could not have found that it was clear as a matter of law that appellant expected no payment or that the benefit was conferred officiously.

CONCLUSION
The court affirmed the finding that the appellant could not recover under a contract theory, but reversed as to the unjust enrichment cause of action. It was not clear that as a matter of law, appellant expected no payment or that the benefit was conferred officiously.

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1 comment:

  1. Schott v. Westinghouse
    o ISSUE: Did the company become contractually obligated to one of its employees as a result of the program, where company promised to pay employee if suggestion was adopted, and employee submitted suggestion which he claimed was adopted, but which company claims it rejected?
    HOLDING: Schott can’t recover under contract theory, but possibly can for unjust enrichment, so his claim should not be dismissed for a demurrer.
    § PL would need to show that D was unjustly enriched at his expense and that his idea was reduced to concrete form, and is novel, and that he didn’t offer the idea gratuitously and intended to be compensated.
    o Dissent – contract was formed, it was fully executed, therefore what happened years later doesn’t matter.

    ReplyDelete

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