Lawrence v. Ingham County Health Department Family Planning/Pre-Natal Clinic
Michigan Court of Appeals
408 N.W.2d 461 (Mich. Ct. App. 1987)
The Lawrences (plaintiffs) received prenatal care from the Ingham County Health Department Family Planning/Pre-Natal Clinic (Clinic) (defendant), and their daughter suffered prenatal asphyxia causing permanent brain damage; they sued for breach of an implied contract, alleging the Clinic's offer to provide care meeting applicable standards was accepted through their own promises not to have an abortion and to follow the doctors' directions, which they claimed constituted consideration. The trial court granted the Clinic summary judgment, and the Lawrences appealed.
Whether, for a promise to rise to the level of consideration sufficient to support an implied contract, the promise must be of some value to the other party.