L. U. Pitts (plaintiff) was an independent contractor for McGraw-Edison Company (defendant). Pitts and McGraw did not have an employment contract, and the relationship was terminable by either party at will. Pitts did not make any contributions to a retirement fund during his relationship with McGraw. When Pitts was 67 years old, McGraw sent a letter informing him that he would be retiring and would be replaced. The letter stated that “to make the matter of retirement a little less distasteful,” McGraw would pay Pitts his typical one percent commission on sales in his territory. McGraw made these payments for five years but then discontinued the payments. Pitts brought suit, claiming that the letter from McGraw constituted an offer that he accepted by retiring. The district court dismissed the complaint. Pitts appealed, claiming he was entitled to continued payments under the doctrine of promissory estoppel because he retired in reliance on the promise in the letter from McGraw.