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Schott v. Westinghouse Electric Corporation

Supreme Court of Pennsylvania

259 A.2d 443 (1969)

Relevant factsFree

Schott (plaintiff), a Westinghouse (defendant) employee, twice suggested switching from aluminum to heavy gauge steel in circuit breaker manufacturing to cut costs, but Westinghouse rejected the suggestions as not cost-effective. Westinghouse's employee suggestion program paid cash awards for adopted cost-saving ideas, though the suggestion form disclaimed liability by making the Suggestion Committee's eligibility and award decisions final. Westinghouse eventually adopted the idea anyway but refused to pay Schott, claiming it arrived at the idea independently. Schott sued for breach of contract; the trial court held the disclaimer controlled and no contract was formed. Schott then amended his complaint to add an unjust enrichment claim, but the trial court again ruled for Westinghouse, holding the Suggestion Committee's decision was final.

IssueFree

Whether, under contract law, a party who has failed to set out a claim for breach of contract may recover under the doctrine of unjust enrichment.

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