Tuesday, March 12, 2013

Cohen v. Cowles Media Company case brief

Cohen v. Cowles Media Company case brief summary
501 U.S. 663

SYNOPSIS: The case was before the court on a writ of certiorari to the Supreme Court of Minnesota, reversing a judgment awarding compensatory damages to plaintiff informer based on a theory of promissory estoppel. The state court concluded that the enforcement of defendants' promise of confidentiality violated defendants' First Amendment rights, because defendant was a newspaper publisher.

-Plaintiff agreed to provide defendant with documents relating to a candidate in an upcoming election, but only if he was given a promise of confidentiality.
-The newspaper nevertheless published the name of the source, and plaintiff was subsequently fired from his job.
-Plaintiff sued for breach of contract and fraud.

-The jury awarded compensatory and punitive damages.
-The court of appeals reversed the award of punitive damages after concluding that plaintiff failed to establish a fraud claim, the only claim that would support such an award.
-The state supreme court reversed the compensatory damages award, concluding that enforcement of the promise of confidentiality under a promissory estoppel theory violated defendants' First Amendment rights.

The Supreme Court reversed, holding that defendant newspaper publisher had no special immunity from the application of general laws and was therefore liable just as any other for breach of contract based on promissory estoppel.

Compensatory damages are a proper remedy to avoid the injustice under a promissory estoppel claim.

-Restatement (second) 90 eliminates the requirement that reliance be definite and substantial and provides that the remedy granted for breach may be limited as justice requires.
-Damages then might be limited to restitution or measured to the extent of plaintiff’s reliance.

OUTCOME: The Supreme Court reversed.

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