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State Bank of Standish v. Curry

Michigan Supreme Court

500 N.W.2d 104 (1993)

Facts

Each winter for 10 years, Robert and Kathleen Curry (defendants) met with State Bank of Standish (bank) (plaintiff) officials to hold preliminary discussions about a loan to cover the Currys’ spring planting expenses. Early each spring, the bank renewed the loan on the same terms as before. By 1985, the Currys had amassed so much debt that the bank changed the terms of repayment. In the 1986 winter meeting, the now financially stressed Currys asked the bank officials for advice on applying for a federal buyout of their farm, which would have wiped out their bank debt. The Currys discussed the matter with the bank’s officials who, although they said nothing specifically about renewing the annual loan, reassured the Currys that the bank would continue supporting them. The bank turned down the Currys’ loan application in May 1986, which was too late for them to arrange either adequate alternative financing or the federal buyout. The bank sued to collect on the Currys’ debt. The trial jury applied the doctrine of promissory estoppel, denied the bank’s petition, and awarded damages to the Currys. The intermediate appellate court reversed, and the Currys appealed to the Michigan Supreme Court.

Rule of Law

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Holding and Reasoning (Boyle, J.)

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Dissent (Riley, J.)

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