Langer v. Superior Steel Corp., 105 Pa. Super. 579, 161 A. 571 (Pa. Super. Ct. 1932)
Langer v. Superior Steel Corp.
Is an employer's written promise to pay a former employee a lifetime monthly stipend, conditioned on the former employee's refraining from employment with competitors, enforceable either as a contract supported by consideration or, alternatively, under promissory estoppel?
A promise is enforceable when supported by consideration—i.e., a bargained-for exchange in which the promisee incurs a legal detriment or confers a legal benefit at the promisor's request. Forbearance of a legal right (such as the freedom to accept employment with competitors) constitutes sufficient consideration when sought in exchange for the promise. Alternatively, under Restatement (First) of Contracts § 90, a promise that the promisor should reasonably expect to induce action or forbearance on the part of the promisee, and which does induce such action or forbearance, is binding if injustice can be avoided only by enforcement.
Yes. The promise was enforceable because Langer's forbearance from working for competing companies, undertaken at Superior Steel's request as a condition of payment, supplied valid consideration. Even if not, the promise was enforceable under promissory estoppel given Langer's reliance.
Langer is frequently taught to show (1) how forbearance of a legal right can supply consideration; (2) how to distinguish a bargain from a conditional gift; and (3) how promissory estoppel can operate as an alternative basis for enforcement. It is an early, influential Pennsylvania decision applying both classical consideration doctrine and Restatement § 90, and it provides a concrete example of a unilateral contract accepted by performance. The case is particularly useful when contrasted with later pension-gratuity cases where no forbearance or other bargained-for element existed.