Hayes v. Plantations Steel Co.
Supreme Court of Rhode Island
438 A.2d 1091 (R.I. 1982)
Edward Hayes (plaintiff) worked for Plantations Steel Co. (defendant) for 25 years and decided on his own to retire at 65. Only after announcing his retirement did a company officer tell him Plantations would "take care" of him, without any formal agreement or specific dollar amount. For four years the company paid Hayes $5,000 annually "as a token of appreciation," and Hayes did not seek other work. When new ownership took over, the payments stopped, and Hayes sued, arguing his retirement was consideration for a pension promise, or alternatively that promissory estoppel should enforce the promise. The trial court ruled for Hayes; Plantations appealed.
Whether a promise to pay a pension can be enforced through contract consideration or promissory estoppel when the promisee's decision to retire was made before, and independent of, the promise.