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Barnett v. BOARD OF TRUSTEES STATE COLLEGES

Louisiana Court of Appeal
809 So. 2d 184, 2001 WL 700809 (2001)
ELI5:

Rule of Law:

A promise for a high-level appointment made by a university official, which is explicitly contingent on approval by the governing Board of Trustees, does not create an enforceable contract or a basis for a detrimental reliance claim if the Board never grants such approval according to its established procedures.


Facts:

  • In January 1995, Northwestern State University (NSU) President Dr. Robert Alost sent a letter to J.D. Barnett confirming a decision to appoint him as Athletic Director, explicitly stating the appointment was 'pending, of course, the approval of the Board of Trustees.'
  • In May 1995, Dr. Alost sent a letter to the University System President requesting Barnett's appointment as Associate Athletic Director effective immediately and as Athletic Director effective July 1, 1996.
  • The formal personnel-change form later submitted to the Board for its June 29, 1995 meeting only requested a title change for Barnett to 'Head Coach Men's Basketball Associate Director of Athletics' with no salary increase and did not mention the Athletic Director position.
  • Within three days of the June 29, 1995 Board meeting, NSU Vice President Jerry Pierce informed Barnett that the Board had not approved his promotion to Athletic Director because the proper form had not been submitted.
  • Dr. Alost retired from his position as NSU President before ever submitting the required personnel forms to the Board for Barnett's appointment as Athletic Director.
  • In May 1996, the new NSU president, Dr. Randy Webb, told Barnett that the Board had never officially appointed him Athletic Director and that the university would conduct a national search for the position.

Procedural Posture:

  • J.D. Barnett filed a lawsuit against the Board of Trustees for State Colleges and Universities in a Louisiana trial court, alleging breach of contract and detrimental reliance.
  • The Board filed a motion for summary judgment, arguing no contract existed and any reliance by Barnett was unreasonable.
  • The trial court granted the Board's motion for summary judgment and dismissed Barnett's claims.
  • Barnett, as appellant, appealed the trial court's judgment to the Court of Appeal of Louisiana, First Circuit.

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Issue:

Does a university president's promise to promote an employee, which is explicitly contingent on approval by the university system's Board of Trustees, create an enforceable contract or a basis for a detrimental reliance claim when the Board never formally approves the promotion?


Opinions:

Majority - Carter, Chief Judge

No. A university president's promise does not create an enforceable contract or a valid detrimental reliance claim without the required formal approval from the Board of Trustees. The court held that no contract was formed because Barnett's promotion to Athletic Director was never properly submitted to the Board for approval as an individual line item, which was required by the Board's own rules. The May 18 letter from Dr. Alost was not a formal submission and could not bind the Board. Barnett failed to provide any factual evidence to prove a contract existed. On the detrimental reliance claim, the court found Barnett's reliance was unreasonable. The initial promise from Dr. Alost was explicitly contingent on Board approval, making any reliance prior to that approval unreasonable. Furthermore, Barnett was informed within days of the Board meeting that the promotion had not been approved, making any subsequent reliance, such as building a larger house, unreasonable. Finally, promises made by Dr. Alost and another administrator could not be legally imputed to the Board itself.



Analysis:

This decision reinforces the legal principle that individuals dealing with government or quasi-governmental entities must ensure that all formal procedural requirements are met. It establishes that promises from individual officials, even high-ranking ones like a university president, are not binding on the governing body if that body's own rules require its formal approval for the action in question. The case heightens the burden for plaintiffs bringing detrimental reliance claims against state agencies, clarifying that reliance is not 'reasonable' when the plaintiff knows or should know that a higher authority's approval is a necessary condition. This precedent protects public entities from being bound by unauthorized commitments and places the onus on employees to verify that proper authorization has been secured.

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