Case Brief Promisoory Estoppel

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Term Research: Promissory Estoppel Case Name: James LoBiondo, (Plaintiff-Respondent) v. Liam O’Callaghan, (Defendant-Appellant), and John Mulheren, (Defendant) Legal Citation: 357 N.J Super. 488;815 A.2d 1013; 2003 N.J. Super Date Decided: February 19, 2003 Legal History: The neighbor and the husband were involved in a discussion concerning the sale of a house owned by the husband and the wife. When the wife found out about the discussion she insisted the house be listed through a realtor. The next day a buyer was found and the neighbor said he was prepared to match the offer. The husband said it was too late. The appellate court held that although an oral contract was enforceable under N.J. Stat. Ann. &25:1-13, the neighbor did not prove by clear and convincing evidence that the wife’s actions have the husband authority to act on her behalf. Therefor the wife did not ratify the husband’s actions. The neighbor could not use the theory of Promissory Estoppel to obtain specific performance of the alleged contract at issue- since there was no “clear and definite” proof of an express promise. Defendants, a husband and a wife, appealed a judgment by Superior Court of New Jersey, Chancery Division, and Monmouth County, which granted specific performance of an oral contract with a right of first refusal to plaintiff neighbor. The owners claim the evidence was insufficient. Facts: LoBiondo (Plantiff) and O’Callaghan (Defendant) had multiple conversations starting in 1996 and spanning over several years regarding LoBiondo’s interest in purchasing O’Callaghan’s house. Nothing was ever put in writing and despite being joint owner on the property; Mrs. O’Callaghan never took part in these discussions. In early 2000 the men met and agreed upon a sale price of $300,000.00. Upon discussing and scheduling necessary repairs to the property, LoBiondo called to follow

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