Goodman v. Dicker – Case Brief
Goodman v. Dicker, 169 F.2d 684 (D.C. Cir. 1948).
Facts: Goodman (D) was the local distributor for Emerson Radio. Goodman encouraged Dicker (P) to apply for an Emerson franchise. Goodman induced Dicker to incur expenses to do business under the franchise including the employment of salesmen and solicitation of orders for merchandise. D represented that P had been approved for a franchise and that he would receive a delivery of 30 radios but later informed P that there would be no deal. P sued D and was granted a judgment of $1500 of which $350 was for expected profits from the sale of the radios. D appealed, asserting that the franchise agreement was at will and therefore there was no liability.
Issue: 1) If a party acts to his detriment on the affirmative assurances of another, should he be protected by estopping the other party from alleging anything in opposition to the natural consequences his own course of action? 2) Are reliance damages proper under promissory estoppel?
Holding and Rule: 1) Yes. If a party acts to his detriment on the affirmative assurances of another, that party can be protected by estopping the other party from alleging anything in opposition to the natural consequences of his own course of conduct. 2) Yes. Reliance damages are proper under promissory estoppel.
D’s conduct lead P to do something that P would not otherwise have done. D cannot subject P to loss or injury by disappointing the expectations upon which P acted. The trial court erred in adding the $350 for loss of profits on the radios promised. The true measure of damages is the loss sustained by expenditures made in reliance upon the assurance of a dealer franchise.
Disposition: Modified and Affirmed.
Notes: Reliance damages are proper under promissory estoppel, however in this jurisdiction expectancy damages are not available for the lost profit from the sale of the radios.