Alden v. Presley – Case Brief
Alden v. Presley, 637 S.W.2d. 862 (Tenn. 1982).
Facts: Alden’s (P) daughter Ginger Alden was a former girlfriend of Elvis Presley. Presley offered to pay for Ms. Alden’s divorce, to pay off her husband’s equity in their home, and to pay off the mortgage. Alden filed for divorce on Sept. 1, 1977 and Presley died on August 16, 1977. The executor of the estate refused to honor the agreement and P sued. The trial court found for Presley on the grounds that the money was a gift but it had not been delivered. The court of appeals reversed and Presley appealed.
Issue: To what extent must a promisee rely on a promise in order for promissory estoppel to render it enforceable?
Holding and Rule: For a promise to be enforceable through promissory estoppel, the promisee must have reasonable detrimental reliance on the promise.
D’s promise induced P to assume a $40,000 mortgage as part of a property settlement, but the settlement was not binding until approved by the court. The element of detrimental reliance is removed because D refused to honor the agreement before submission of the agreement to the court. The court held that P’s reliance was not reasonable.