New Hampshire
How Brown v. Gobble applies in New Hampshire: state-specific rules, key cases, and bar exam notes for Other.
New Hampshire generally adheres to principles of equitable estoppel as established in Brown v. Gobble. The state recognizes that equitable estoppel may prevent a party from asserting a claim or defense that contradicts previous conduct that another party reasonably relied upon.
In New Hampshire, equitable estoppel requires a showing that one party's misleading conduct caused another party to take action or inaction to their detriment, based on the reasonable belief instilled by the first party's conduct.
The court held that equitable estoppel applied because the decedent’s representations about property ownership led the claimant to believe they were entitled to an inheritance.
This case affirmed that a party may not contradict representations made previously if it induces detrimental reliance from another party.
The court ruled that an individual's change in position regarding property rights, after inducing another to rely upon their prior statements, constituted a basis for equitable estoppel.
New Hampshire's approach to equitable estoppel is consistent with federal standards, which also focus on the necessity of a reasonable reliance and resultant detriment. However, New Hampshire courts place greater emphasis on explicit representations made by the parties involved than some federal courts which may interpret estoppel more broadly.
Equitable principles, including those stemming from Brown v. Gobble, are frequently tested on the New Hampshire bar exam. Candidates should familiarize themselves with both the elements and applications of equitable estoppel.