In re Estate of RyanAnnotate this Case
The Supreme Court affirmed in part and reversed and remanded in part the probate court's dismissal of a golf course partnership's claim based upon an unfulfilled pledge agreement in a decedent's probate proceeding, holding that the partnership failed to state a claim based on contract but did state a claim based upon promissory estoppel.
The decedent entered into a written pledge agreement with the golf course partnership under which the decedent would make a gift of $20 million so that the partnership could make improvements to the golf course it operated. The decedent died the next year, and the partnership filed a statement of claim against the estate for the $20 million pledge agreement. The estate denied the claim. The partnership then filed a petition for allowance of claim, claiming that the pledge agreement was an enforceable, binding obligation against the estate and, alternatively, that the petition should be granted under a promissory estoppel theory. The probate court dismissed the petition for failure to state a claim. The Supreme Court reversed in part, holding (1) because the partnership was not a charitable, educational, or like institution, its attempt to enforce the pledge agreement as a contract failed; but (2) the partnership stated a claim under a promissory estoppel theory.