Cohen v. Cowles Media Co.

Dan Cohen (plaintiff) gave two Minnesota newspapers damaging information about a lieutenant governor candidate in exchange for reporters' promises of anonymity, but the papers' editors overruled those promises and published his name, leading to his firing that same day. A jury awarded Cohen $200,000 in compensatory damages plus punitive damages on fraud and contract theories; on appeal, the fraud verdict was set aside, and the Minnesota Supreme Court initially held Cohen could not recover on either a contract or promissory estoppel theory, reasoning the latter would violate the newspapers' First Amendment rights. The U.S. Supreme Court reversed on the First Amendment question and remanded for the Minnesota court to reconsider promissory estoppel on its own terms.