Case: Parties

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Grouse v. Group Health Plan, Inc 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: plaintiff's part Reversed and remanded. There was sufficient reliance on

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).