Case: Grouse v.

Group Health Plan, Inc

Parties: Plaintiff - Grouse (appellant)

Defendant - Group Health Plan, Inc.

Procedural History: Trial court judgment for defendant. Plaintiff appeals to

Minnesota Supreme Court

Facts: Grouse had a steady, full-time job working at a retail pharmacy. He was
seeking other employment and contacted defendant, Group Health Plan, regarding a
position they were seeking candidates for. He interviewed with Group Health, and
later defendant's chief pharmacist, Elliot, offered him the position. Grouse
informed Elliot he needed to give him current employer 2 weeks notice. Grouse was
also offered a position at another company, but declined because of his acceptance
to work for Group Health. Elliot later became aware that for the position to be
filled, favorable written references were needed. When he couldn’t get any for
Grouse, another candidate was hired. When Grouse called Elliot to inform him he
was available to begin working, Elliot informed him that the position had been
filled by someone else. Grouse experienced difficulty regaining full-time
employment, and suffered wage loss as a result. He then commenced this suit to
recover damages; the trial judge found that he had not stated an actionable claim.

Issue: Does promissory estoppel exist here, that can enforce the promise of
employment made by the defendant?

Arg: Defendant argues that it is at will employment and any employee can be let go
at any time, including after the first day. So, there would be no difference
between letting the employee go the day before or after the first day.

Holding/Judgment: Reversed and remanded. There was sufficient reliance on

plaintiff's part

Reasoning: Plaintiff not only quit his then current employment, but declined
another offer for employment based on reliance for his being hired at Group
Health. Elliot knew that Grouse would have to resign his employment and so knew
plaintiff was relying on the job offer made to him. The court holds that this
decision does not imply that an employer is liable whenever he discharges an at
will employee. Instead it holds that the plaintiff had a right to assume he would
be given a good faith opportunity to perform his duties to the satisfaction of
Group Health once he was on the job. However, as the def points out, he was at
will, and could have been discharged at any time, so the damages compensated would
not be so much, but only the amount he lost in quitting his job and declining the
other employment.
Reliance damages, - he left his old job, he turned down another offer.
Court found for plaintiff on promissory estoppel, because he was induced to take
certain actions because of his reliance.

• The defendant has done or said something to induce an expectation

• Def offered plaintiff a job. They could have reasonably expected plaintiff
to quit his current job. Reasonable and foreseeable that this type of promise
would have created this type of response/action of the prospective employee.
• The plaintiff relied (reasonably) on the expectation…
• Yes, he acted in reliance
• ...and would suffer detriment if that expectation were false.
• Damages given with respect to his loss of wages, and lost opportunity

Employment at will - could be fired for any reason except an illegal reason
(discrimination, retaliation, etc).