Corbit v. J. I. Case Co.

424 P.2d 290 · Washington Supreme Court · 1967

Facts

Philip and Shirley Corbit, through Corbit Equipment Co., sought to establish J. I. Case dealerships in Spokane, requiring a warehouse. This involved negotiations with J. I. Case, Northern Pacific Railway for land, and Whitworth College for warehouse construction and lease-back. The complex arrangement collapsed, leading the Corbits to sue all parties for breach of contract, promissory estoppel, and conspiracy.

Issue

The court considered whether there was sufficient evidence to prove a civil conspiracy among the defendants, an "over-all contract" binding all parties, or individual contracts and promissory estoppel claims against Whitworth College and Northern Pacific Railway, and whether J. I. Case's liability required a new trial.

Holding

The court reversed the conspiracy judgment against all defendants, finding insufficient evidence. It also reversed judgments based on an "over-all contract" against Northern Pacific and Whitworth. The court found no individual contracts or promissory estoppel claims against Whitworth (due to lack of agent authority) or Northern Pacific (due to unfulfilled conditions and lack of reliance). A new trial was ordered for J. I. Case regarding its individual contractual and promissory estoppel liability due to jury instruction confusion.

Rule

Civil conspiracy requires clear, cogent, and convincing evidence of an agreement to an unlawful purpose or lawful purpose by unlawful means. Contract formation requires mutual assent, valid offer and acceptance, and agent authority. Promissory estoppel requires a clear promise, foreseeable and actual reliance of a definite and substantial character, and that injustice can only be avoided by enforcement.

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Case brief last reviewed 2026-03-19. Prepared by CaseReader from the published opinion.