Wednesday, December 4, 2013

Ypsilanti v. General Motors case brief

Ypsilanti v. General Motors case brief summary
506 N.W.2d 556 (1993)

CASE SYNOPSIS
Defendant corporation challenged a judgment from the Washtenaw Circuit Court (Michigan), which found that the corporation was bound to plaintiff governments by promissory estoppel and enjoined the corporation from transferring some of its production from a local plant to another facility.

CASE FACTS
The corporation was given a tax abatement for a number of years after establishing that it would create jobs. When the corporation announced that it intended to move its production to another facility, the governments filed an action against the corporation for breach of contract, promissory estoppel, unjust enrichment, and misrepresentation. When the trial court determined that the corporation was bound by promissory estoppel and enjoined the corporation from moving its production, the corporation sought review.

DISCUSSION
  • On appeal, the court reversed and found that an actual, clear, and definite promise was required to show promissory estoppel. 
  • The court reasoned that the corporation's solicitation of a tax abatement did not constitute a promise. 
  • The court further found that the corporation was required to give representations regarding employment in order to receive a tax abatement, pursuant to Mich. Comp. Laws § 207.559(2)(e) (Mich. Stat. Ann. § 7.800(9)(2)(e)). 
  • Finally, the court held that the corporation's use of hyperbole to gain an advantage did not amount to a promise.

CONCLUSION
The court reversed the decision of the trial court, which enjoined the corporation from moving its production from a local plant to another facility after finding that the corporation was bound to the governments under the doctrine of promissory estoppel.

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