Michie v. Board of Trustees
Wyoming Supreme Court
847 P.2d 1006 (1993)

- Written by Emily Laird, JD
Facts
Dr. David Michie served on the school district’s board of trustees (the school board) (defendant) for seven years. In 1984, during Dr. Michie’s tenure on the school board, the board’s attorney opined that board members could participate in the school district’s insurance plan if the members paid their own premiums. The school board’s attorney also stated that board members could remain on the plans after their terms of service on the school board ended. The school board then moved to allow board members to participate in the school district’s insurance plan. Dr. Michie and at least one other school-board member canceled their personal insurance policies and enrolled in the school district’s policy. In 1989, a year after Dr. Michie stopped serving on the school board, a new school board voted unanimously to disallow health-insurance participation by past or present board members. Dr. Michie and his wife (plaintiffs) filed a claim against the school board in state court, alleging promissory estoppel. The state district court granted the school board’s motion to dismiss the estoppel claim, citing the lack of an enforceable contract. Dr. Michie appealed to the state supreme court, arguing that a claim for promissory estoppel does not require an enforceable contract. Dr. Michie argued that he should be entitled to relief because he detrimentally and reasonably relied on the promises of the school board. The school board argued that it had the right to create new policies and that it was not bound to the contracts or promises made by previous school boards.
Rule of Law
Issue
Holding and Reasoning (Macy, C.J.)
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