Garwood Packaging, Inc. v. Allen & Company, Inc.
United States Court of Appeals for the Seventh Circuit
378 F.3d 698 (2004)
GPI (plaintiff), deeply in debt, hired Allen (defendant) to find investors; Allen's VP Martin told GPI that Allen would invest $2 million if a matching investor joined, and identified Hobart as that matching investor — but Hobart, along with other contributing investors Allen lined up, all insisted on releases from GPI's existing creditors, some of whom GPI knew were unwilling to sign such releases. Despite this known obstacle, Martin assured GPI the deal would go through "come hell or high water," prompting GPI to forgive personal loans and relocate officials near Hobart's proposed plant; the investment ultimately fell through when Martin withdrew Allen's $2 million. GPI sued under promissory estoppel, and the district court granted Allen summary judgment.
Whether promissory estoppel requires that a promisee's reliance on a promise be reasonable.