Yes, that statement was a real promise in this situation. A promise doesn't have to be a signed contract with every detail spelled out. We have to look at the whole story. The Currys were making a huge life decision—quit farming or keep going—and they asked the bank directly if they'd get the loan. When the bank said 'we'll support you,' it was reasonable for the Currys to believe that meant 'yes, you'll get the loan.' Even though they didn't discuss the interest rate right then, everyone knew what the terms would be based on the last ten years of loans. The bank's words created a trust that they broke.

No, 'we'll support you' is way too vague to be a legal promise. Business deals, especially big loans, need to be clear. You can't sue someone over a fuzzy statement like 'we'll support you.' What does that even mean? What was the exact loan amount, interest rate, or payment plan? None of that was agreed upon. Also, the Currys' farm was losing money, so it was unreasonable to expect the bank to keep lending them money just because they had in the past. This was just a friendly, encouraging chat, not a binding promise.

Yes, there was enough evidence that the bank made a clear promise to the Currys. When we look at all the facts in the way that's most favorable to the Currys, it seems the bank clearly said they would keep lending money to the Currys for their spring planting. This wasn't just general talk about maybe helping in the future. The Currys specifically asked if they should keep farming or take the government's offer, and the bank told them not to worry because the bank would support them. Even though the bank didn't spell out all the details of the loan, we can figure those out based on how they've done loans for the Currys in the past 10 years. It was fair for the jury to decide that the bank made a real promise, not just said some nice words. So we're saying the jury was right, and the Currys win their case.

No, I don't think there was enough evidence of a clear promise from the bank. Saying they would 'support' the Currys is too vague, especially when we're talking about complicated business loans. The bank didn't say how much money they would lend, what the interest rate would be, or how the Currys would pay it back. These are important details for a real promise about a loan. Also, the way the bank and the Currys did business had changed recently, so we can't assume they'd do things the same as before. The Currys' farm was having money troubles, which also changes things. Even if we look at the evidence in the way that's best for the Currys, I don't think the bank's words were clear enough to count as a real promise that they have to keep. If we force banks to keep vague promises like this, it could make it hard for them to change their decisions when the economy changes. I think the other judges who said the Currys should lose were right.

Yes, a bank's statement of support, given the context, can constitute a clear and definite promise. A promise is a 'manifestation of intention to act... so made as to justify a promisee in understanding that a commitment has been made.' To determine if a promise exists, courts must look to the words and actions, the nature of the parties' relationship, and the surrounding circumstances. Here, the bank's assurances were not made in a vacuum but in a specific conversation where the Currys were deciding whether to continue farming or exit the business, a decision that hinged on receiving the loan. The jury was entitled to find these were not mere words of encouragement but a promise of future action. Although the material terms of the loan were not explicitly restated, they could be objectively determined from the parties' ten-year history of customary loan practices, which established the interest rate, repayment method, and collateral.

No, the bank's general statements of support were not clear and definite promises sufficient for promissory estoppel. The doctrine of promissory estoppel is an exception to contract rules and requires that a promise be 'clear and plain' and 'definite and clear,' especially in complex commercial financing. The bank's pledges of 'support' were 'vaporous and amorphous,' with no specified material terms like the loan amount, interest rate, or payment schedule. Furthermore, any prior course of dealing was altered by the Currys' rapidly deteriorating financial situation, including mounting debt and significant losses, and a recent change in loan repayment terms from a rollover basis to an annual payment basis. Enforcing such vague statements would improperly paralyze a lender's ability to adjust to a borrower's changing financial health.

Yes, there was sufficient evidence of a clear and definite promise to support the Currys' claim of promissory estoppel. The evidence, viewed in a light most favorable to the Currys, showed that the bank made a clear manifestation of intention to continue extending credit to finance the Currys' farming operation for the upcoming spring planting season. This promise was made in the context of the Currys' specific inquiry about whether they should continue dairy farming or enter the government buy-out program. The material terms of the loan could be determined from the nature of the transaction and the ten-year history of customary loan practices between the parties. While general discussions or past renewals of credit alone may not create a binding promise, here there was more specific assurance given in response to the Currys' direct inquiry about their future financing. The existence and scope of a promise are questions of fact, and the jury was entitled to find that the bank's statements were not merely words of assurance but a promise of future action. The Court of Appeals erred in finding insufficient evidence as a matter of law. We therefore reverse in part, reinstate the jury's verdict in favor of the Currys, and remand for further proceedings.

No, there was not sufficient evidence of a clear and definite promise to support the Currys' claim of promissory estoppel. The bank's statements of 'support' were too vague and ambiguous to constitute the clear and definite promise required for promissory estoppel, especially in the context of complex commercial financing. No specific terms of the loan were specified, such as the amount, interest rate, or payment schedule. The recent change from rollover to annual payment terms disproves any notion of established customary practices between the parties. The Currys' deteriorating financial circumstances also altered any established norms. Even viewing the evidence in the light most favorable to the Currys, the bank's statements lacked the necessary definiteness to justify application of promissory estoppel. Enforcing such ambiguous promises of future financing would be inequitable and permit speculative damages. The majority's approach risks paralyzing lenders' ability to adjust to changing market conditions once a lending relationship is established. I would affirm the Court of Appeals' reversal of the jury verdict.

State Bank of Standish v. Curry

Case Podcast

Rule of Law:

The Legal Principle

Facts:

Procedural Posture:

How It Got Here

Issue:

Legal Question at Stake

Opinions:

Majority, Concurrences & Dissents

Analysis:

Why This Case Matters

Gunnerbot