RAVELO BY RAVELO v. County of Hawaii
66 Haw. 194, 1983 Haw. LEXIS 110, 658 P.2d 883 (1983)
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Rule of Law:
A promise is enforceable under the doctrine of promissory estoppel if the promisor should reasonably expect the promise to induce action or forbearance, the promise does induce such action or forbearance, and injustice can be avoided only by enforcement of the promise.
Facts:
- On December 13, 1978, the County of Hawaii Police Department informed Benjamin Ravelo by letter that his application for employment as a police officer had been accepted and he would be sworn in on January 2, 1979.
- In reliance on the County's promise of employment, Benjamin Ravelo resigned from his position as a police officer with the Honolulu Police Department.
- At the same time, Marlene Ravelo resigned from her job in anticipation of the family's move.
- The Ravelos also informed their children's private school that they were unenrolling them.
- On December 20, 1978, the County of Hawaii Police Department informed Benjamin Ravelo that he was not going to be hired.
- Both Benjamin and Marlene Ravelo attempted to rescind their resignations but were informed by their respective employers that it was too late to get their jobs back.
Procedural Posture:
- Benjamin and Marlene Ravelo filed a complaint against the County of Hawaii in the Circuit Court of the Third Circuit (a state trial court).
- The County of Hawaii filed a motion to dismiss the complaint for failure to state a claim upon which relief could be granted.
- The circuit court granted the County's motion and dismissed the Ravelos' complaint without prejudice.
- The Ravelos filed a motion for reconsideration, which the circuit court denied.
- The Ravelos then filed a motion to amend their complaint, which the circuit court also denied.
- The circuit court granted the Ravelos, as plaintiffs-appellants, leave to pursue an interlocutory appeal to the Supreme Court of Hawaii.
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Issue:
Does a complaint state a claim for which relief can be granted under the doctrine of promissory estoppel when it alleges that the plaintiffs resigned from their jobs in reasonable reliance on a promise of employment that was later rescinded?
Opinions:
Majority - Nakamura, J.
Yes, a complaint states a claim for relief under promissory estoppel where plaintiffs allege detrimental reliance on a promise of employment. Even if a claim for breach of a formal contract fails, a plaintiff may be entitled to relief under alternative theories. This court adopts the doctrine of promissory estoppel as articulated in the Restatement (Second) of Contracts § 90, which makes a promise binding if it reasonably induces action or forbearance and injustice can only be avoided by its enforcement. The County's promise of employment at a definite time could have been reasonably expected to induce the Ravelos to quit their jobs. Because they did so in reliance on that promise, their complaint states a cognizable claim, and the remedy may be limited as justice requires to cover their reliance damages.
Analysis:
This case is significant for formally adopting the modern, more flexible standard for promissory estoppel from the Restatement (Second) of Contracts § 90 in Hawaii. The decision expands the doctrine's application by eliminating the prior requirement that the induced action be of a 'definite and substantial character.' This lowers the bar for plaintiffs bringing such claims and provides a basis for recovery based on reasonable reliance, even without a formal contract. Furthermore, the court's adoption of the Restatement's provision for partial enforcement allows for remedies tailored to the plaintiff's actual reliance losses rather than full expectation damages, creating a more equitable balance.
