Ohio
How Dunn v. State of Missouri applies in Ohio: state-specific rules, key cases, and bar exam notes for Contracts.
Ohio recognizes the principle of promissory estoppel similarly to Missouri as established in Dunn v. State of Missouri. Particularly, Ohio courts enforce promises that induce reasonable reliance, even in the absence of formal consideration.
In Ohio, a promise is enforceable if the promisor should reasonably expect the promise to induce action or forbearance on the part of the promisee, and such action or forbearance is taken in reliance on the promise.
The Ohio court held that a landlord's oral promise was enforceable where the tenant relied on it to their detriment.
This case affirmed that government promises can create enforceable expectations when reliance is reasonable.
Established that reliance on a promise must be both reasonable and foreseeable to be enforceable in Ohio.
Like the federal standard under the Restatement (Second) of Contracts, Ohio's application of promissory estoppel requires reliance on enforceable promises. However, state courts emphasize the reasonable foreseeability of reliance more rigorously compared to some federal interpretations.
Questions regarding promissory estoppel and its application in Ohio often appear on the bar exam, particularly in contracts sections.