Cochran v. Robinhood Lane Baptist Church

Reverend Eugene Cochran was the pastor at Robinhood Lane Baptist Church (the church) (defendant) for many years. In exchange for these services, the church paid Eugene a salary and provided additional benefits, such as cell-phone and beeper services, lawn services, gas, and vehicle maintenance. Under an oral agreement between the church and Eugene, the church also provided those benefits to Eugene’s wife, Annie Cochran (plaintiff). After Eugene died, the church and Annie entered a contract in which the church promised to give her $783.56 twice per month for 15 years and to provide lawn care until she moved. The contract stated that Annie’s benefits would end early if she died or remarried. The contract also terminated the other benefits Annie had received under the oral agreement. Shortly after, the church stopped paying Annie. Annie sued the church for breaching the contract. Annie argued that she had provided consideration to support the contract by: (1) continuing to attend church in her role as first lady of the church, (2) relinquishing her benefits under the oral agreement, and (3) declining a marriage proposal after entering the contract. Alternatively, Annie argued that if the contract lacked consideration, it should be enforced under the promissory-estoppel doctrine. The trial court granted summary judgment for the church. Annie appealed to the Tennessee Court of Appeals.