Norton v. McOsker
2005 U.S. App. LEXIS 9042, 2005 WL 1177227, 407 F.3d 501 (2005)
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Rule of Law:
A claim for promissory estoppel to enforce a promise of lifetime support arising from a non-marital relationship fails if the promise is not clear and unambiguous and if the promisee's reliance is unreasonable. Furthermore, ending a long-term adulterous affair, while emotionally distressing, does not rise to the level of extreme and outrageous conduct required for a claim of intentional infliction of emotional distress.
Facts:
- In 1974, Gail M. Norton began an adulterous relationship with Russell L. Hoyt, who was married but initially led Norton to believe he was divorced.
- Shortly after the relationship began, Norton learned Hoyt was married, but he told her he was in the process of getting a divorce.
- Over the next 23 years, Hoyt repeatedly promised that he would divorce his wife, marry Norton, and support her for the rest of her life.
- In 1980, Norton resigned from her job as a school teacher, allegedly in reliance on Hoyt's promises and at his urging, to be more available to him.
- Throughout the relationship, Hoyt provided Norton with an extravagant lifestyle, including travel, shared homes, cars, and general financial security.
- Norton became pregnant by Hoyt at one point but suffered a miscarriage.
- Hoyt remained married to his wife throughout the entire 23-year relationship with Norton.
- In March 1998, Hoyt formally ended his relationship with Norton.
Procedural Posture:
- Gail M. Norton sued Russell L. Hoyt in Rhode Island Superior Court (a state court of first instance), asserting claims for promissory estoppel and intentional infliction of emotional distress, among others.
- Hoyt, invoking diversity jurisdiction, removed the case to the United States District Court for the District of Rhode Island.
- The district court dismissed several of Norton's claims.
- The district court then granted Hoyt's motion for summary judgment on the remaining claims of promissory estoppel and intentional infliction of emotional distress.
- Norton (appellant) appealed the district court's grant of summary judgment to the U.S. Court of Appeals for the First Circuit, with Hoyt's estate as the appellee.
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Issue:
Does a promise for lifetime support, made during a long-term adulterous relationship, create an enforceable obligation under the doctrine of promissory estoppel when the promise is vague and the promisee continues to rely on it for over two decades despite the promisor's repeated failure to fulfill related promises?
Opinions:
Majority - Torruella, Circuit Judge
No. A promise for lifetime support from a long-term adulterous relationship is not enforceable under promissory estoppel where the promise is vague and reliance on it is unreasonable. The court affirmed the lower court's grant of summary judgment for Hoyt. For the promissory estoppel claim to succeed under Rhode Island law, there must be a clear and unambiguous promise, reasonable reliance, and resulting detriment. Hoyt's alleged promise to 'take care of' Norton was too vague and indefinite to be legally enforceable. Furthermore, Norton's reliance was unreasonable as a matter of law; she knew Hoyt was married and he had continuously failed to fulfill his promise to divorce his wife for 23 years. The court also characterized her claim as one for 'palimony,' a cause of action not recognized in Rhode Island. Regarding the intentional infliction of emotional distress (IIED) claim, the court found Hoyt's conduct did not meet the required 'extreme and outrageous' standard. Merely breaking up a long-term extramarital affair, while emotionally painful, is not conduct that is 'beyond all possible bounds of decency' and 'utterly intolerable in a civilized community.' Hoyt was exercising his legal right to end the relationship.
Analysis:
This decision reinforces the high bar for promissory estoppel claims, particularly in the context of personal or romantic relationships, requiring specific, clear promises and objectively reasonable reliance. It demonstrates the judiciary's reluctance to create new state-law causes of action, such as 'palimony,' when sitting in diversity, preferring to wait for the state's highest court to do so. The ruling also clarifies that the inherent emotional pain from the dissolution of a long-term relationship, without more egregious conduct, does not meet the 'extreme and outrageous' standard for intentional infliction of emotional distress, thereby protecting an individual's right to end a relationship without facing tort liability for the resulting heartbreak.
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