Defendant bank appealed the judgment entered against it on the special verdict of a jury by the Superior Court of San Diego County (California) in suit filed by plaintiffs, company and shareholder, for breach of contract. Defendant argued that a jury trial was not available to plaintiffs whose cause of action was based upon the equitable doctrine of promissory estoppel. Plaintiffs cross-appealed.
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Overview
Plaintiffs, company and shareholder, filed suit against defendant bank for breach of contract based on an alleged accord and satisfaction between the parties. During the course of trial, plaintiffs amended their complaint to include a theory of recovery based upon promissory estoppel. The trial court found no consideration to support a contract, but sent the issue of promissory estoppel to the jury over the strong objections of defendant. The jury returned a special verdict in favor of plaintiffs and defendant appealed. Plaintiffs cross-appealed. The court reversed the judgment and remanded the case. The court held that plaintiffs’ cause of action, when submitted to the jury, relied entirely upon the equitable doctrine of promissory estoppel because the trial court correctly determined as a matter of law that there was no consideration to support the alleged contract. Because the action was equitable in nature, neither party was entitled to a jury trial under Cal. Const. art. I, §16. Because of the necessity to reverse on the equitable claim, the court declared that all other issues raised in the appeal and the cross-appeal were moot.
Outcome
The court reversed the judgment and remanded the case because plaintiffs, company and shareholder, were not entitled to a jury trial as their cause of action for breach of contract against defendant bank was based entirely upon the equitable doctrine of promissory estoppel. The issues implicated in plaintiffs’ cross-appeal were mooted by the necessity to reverse on the equitable claim.