Weitz Company, LLC v. Hands, Inc.
Supreme Court of Nebraska
294 Neb. 215 (2016)
H & S (defendant) submitted a subcontractor bid to general contractor Weitz (plaintiff) for plumbing and HVAC work, which Weitz incorporated into its own bid to Good Samaritan for a nursing facility project; after Good Samaritan awarded Weitz the contract, H & S refused to honor its bid, and Weitz, unable to withdraw its own already-submitted bid, had to hire a more expensive replacement subcontractor. Weitz sued under promissory estoppel; the trial court ruled for Weitz, and H & S appealed.
Whether recovery on a promissory estoppel theory requires showing the defendant made a promise it should have reasonably expected would induce the plaintiff's action or forbearance, that the promise did induce that action, and that injustice can only be avoided by enforcing the promise.