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Lige Dickson Co. v. Union Oil Co. of California

Washington Supreme Court
635 P.2d 103 (1981)


Facts

Union Oil Company of California (Union Oil) (defendant) encouraged and aided Lige Dickson Company (Lige) (plaintiff) in entering the asphalt-paving business, after which Lige purchased nearly all of its liquid asphalt from Union Oil. Union Oil gave Lige an oral guarantee that it would not increase the price of liquid asphalt for any of Lige’s existing contracts and that any price increase would apply only to contracts entered into after that point. Union Oil later raised the price of liquid asphalt on all of Lige’s purchases. Lige sued Union Oil for its costs in acquiring asphalt to perform its existing contracts. The district court held that the oral contract between the parties was unenforceable, because it did not satisfy the statute of frauds. Lige appealed. The United States Court of Appeals for the Ninth Circuit certified the question to the Washington Supreme Court of whether an oral promise that falls under the statute of frauds could be enforceable on the basis of promissory estoppel.

Rule of Law

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Issue

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Holding and Reasoning (Dore, J.)

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  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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