Valley Bank v. Dowdy
Supreme Court of South Dakota
337 N.W.2d 164 (1983)
Dowdy (defendant) agreed to buy a tractor trailer from Weeks Brothers for $16,000, financed by Valley Bank (plaintiff), which held the truck's title and gave Weeks Brothers the funds; Dowdy took possession, used the truck, made no payments toward the $16,000, and eventually moved out of state with it. Dowdy counterclaimed that he detrimentally relied on Valley Bank's promise to transfer him title by spending $6,658 of his own money and time on maintenance and repairs, expecting title would follow; the trial court awarded Valley Bank possession of the truck but also ordered it to compensate Dowdy for his repair costs, and both parties appealed.
Whether promissory estoppel protects a promisee who has not suffered any detriment by relying on a promisor's promise.