Ricketts v. Scothorn
57 Neb. 51, 77 N.W. 365 (Neb. 1898)

  • A grandfather told his granddaughter that she didn’t need to work anymore and gave her a promissory note for $2k.
    • The granddaughter immediately quit her job and remained jobless for over a year.
  • Then the grandfather died without giving her the $2k. She sued the estate for the money.
    • The estate argued that there was never a contract, the $2k was simply a naked promise, and those are unenforceable.
    • The granddaughter argued that she had relied on the money to her detriment (she quit her job), and it wouldn’t be fair to not give her the money.
  • The Court found for the granddaughter.
    • The Court found that the grandfather had intentionally influenced the granddaughter to alter her position for the worse on faith of a note being paid when due.
    • Therefore, even though a contract was never formed, the estate was still liable to pay the money due to promissory estoppel.
      • “The expenditure of money or assumption of liability by the donee on the faith of the promise is the true reason for the preclusion of the defendant, under the doctrine of estoppel.”