If You’re Going to Plead Promissory Estoppel, Be Specific!

I just wrote up a promissory estoppel case last week, and here’s another one out of Connecticut, Sorrentino v. Rizza, Docket Number CV156013599 (behind paywall). In this case, the plaintiff failed to allege specific enough statements to form the foundation of her promissory estoppel claim. The case is a dispute over a promise of employment, and the relevant part of the complaint alleged that the defendant had promised the plaintiff “on several occasions” that she would be given “a similar position” with the defendant’s company as the plaintiff already held in another company, with “a salary plus a percentage of any advertisement revenue she generated.” 

This was, in the court’s view, “nebulous at best.” No specific dates or locations were given for the promises in question, there was no explanation of the salary that was discussed, and there were no details about what percentage of revenues the plaintiff had been promised. The plaintiff’s allegations were about indefinite statements that seemed to lack any material terms. The court said those could not be construed as any “clear and definite promise” that could the plaintiff could reasonably have relied on. 

So if you think you have a promissory estoppel claim, the lesson from this case is to make sure you are very specific in relaying to the court exactly what was said and when.