Weavertown Transport Leasing, Inc. v. Moran
834 A.2d 1169 · Superior Court of Pennsylvania · 2003
Facts
Moran, an employee of Weavertown, secured season ticket licenses for Pittsburgh Steelers games. Weavertown, seeking tickets for client entertainment, paid the license fees and season ticket costs directly to the Stadium Building Fund and the Steelers, believing Moran would transfer the licenses to the company. After Moran resigned, he refused to transfer the licenses, leading Weavertown to sue for specific performance.
Issue
Did Weavertown's payments to the Stadium Building Fund and the Pittsburgh Steelers constitute valid consideration for an oral agreement with its employee, Moran, to transfer season ticket licenses, or alternatively, did promissory estoppel apply?
Holding
No. The court held that the payments did not constitute consideration because the Steelers and Stadium Building Fund were merely incidental beneficiaries, not intended beneficiaries. Furthermore, the court found that promissory estoppel did not apply as Weavertown did not demonstrate definite and substantial reliance on Moran's promise.
Rule
Consideration requires a bargained-for exchange where the detriment incurred by the promisee is the "quid pro quo" for the promisor's promise. A third party is an intended beneficiary, capable of providing consideration, only if the parties intended to benefit them and performance satisfies an obligation or indicates intent to benefit. Promissory estoppel applies when a promise induces definite and substantial action or forbearance, and injustice can only be avoided by enforcement.
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