Pitts v. McGraw-Edison Co.
United States Court of Appeals for the Sixth Circuit
329 F.2d 412 (1964)
L.U. Pitts (plaintiff) was an at-will independent contractor for McGraw-Edison Company (defendant) with no employment contract or retirement fund contributions; at age 67, McGraw sent him a letter announcing his 'retirement' and replacement, offering to continue paying his usual one-percent sales commission 'to make the matter of retirement a little less distasteful.' McGraw paid these amounts for five years before stopping, and Pitts sued, arguing the letter was an offer he accepted by retiring, and that he was entitled to continued payments under promissory estoppel because he retired in reliance on McGraw's promise; the district court dismissed the complaint.
Whether a promise is enforceable under the doctrine of promissory estoppel if the promisee does not actually change his circumstances in response to the promise.