Para 1 Memo 2
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Jun 3, 2024
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Para 1 Memo 2 Due April 13, 2024
OFFICE MEMORANDUM OF LAW
TO: Barry H. Barker
FROM: Paralegal
DATE: April 13, 2024
CASE: Doyle’s Tavern v. State
OFFICE FILE NUMBER: 24-5555
KIND OF CASE: Breach of contract
DOCKET NUMBER: 24000011
I. Introduction
You have asked me to examine the weakness and strengths of our client John Doyle’s case and analyze whether Doyle’s Tavern has a viable claim against the State for detrimental reliance/quasi breach of contract.
II. Issue and Summary Conclusion
Issue:
Does Doyle’s Tavern have a claim for detrimental reliance against the State because they Governor Kennedy cancelled all indoor events and activities that were scheduled to
resume on July 1
st
. Summary Conclusion: No, Doyle’s Tavern does not have a claim for detrimental reliance. The COVID-19 pandemic had many unforeseeable conditions, it will be difficult to argue.
III. Facts
In early March 2020, the State mandated the shutdown of bars and restaurants due to the COVID-19 pandemic. On June 15, 2020, State Governor Jane Kennedy publicly announced that bars and restaurants could partially reopen on July 1, 2020, for indoor dining with restrictions. Once Governor Kennedy announced the indoor lift, our client Doyle’s Tavern, received numerous reservations, booked three weddings, and ordered $15,000.00 worth of fresh vegetables, lobsters, meats, kegs of craft draft beer, liquors, champagne, and fine French wines to
accommodate the reservations and influx of indoor patrons. On June 27, 2020, Governor Kennedy rescinded the reopening order due to increasing COVID-19 cases, causing Doyle’s Tavern to incur losses on unused supplies.
IV. Rule
State Code Art. 2 § 1423. Cause defined; detrimental reliance:
A party may be obligated by a promise when he knew or should have known that the promise would induce the other party to rely on it to his detriment and the other party was reasonable in so relying. Recovery may be limited to the expenses incurred or the damages suffered as a result of the promisee's reliance on the promise. Reliance on a gratuitous promise made without required formalities is not reasonable.
In Gold Finger’s Casino, Inc. v. State Department of Taxes
, 123 State 2d 456 (2000), the plaintiffs, Gold Finger’s, paid sales taxes under a newly enacted Casino law that was, in their accountant’s opinion, vague and conflicting. Gold Finger’s general manager contacted the Department of Taxes where an employee assured them that no taxes were due for that year. Two years later, the Department claimed that Gold Finger’s owed $30,000.00 in back taxes and penalties for the year in question. The trial court and State Court of Appeal found that although the taxes were due, the state was precluded from collecting them because of the doctrines of detrimental reliance and equitable estoppel. On further appeal, State Supreme Court disagreed finding that “detriment resulting from reliance simply has not been proved.”
V. Analysis
Though our client was reliant on the public announcement made by State Governor, Jane Kennedy, stating that bars and restaurants could open on July 1, 2020. Based on State Code Art. 2 § 1423 Doyle’s Tavern does not have strong case for detrimental reliance against the State based on Governor Kennedy's announcement. The case of Gold Finger’s Casino, Inc. v. State Department of Taxes provides additional insight. While the Supreme Court noted four factors required to invoke detrimental reliance against a governmental agency, including unequivocal advice, reasonable reliance, extreme harm, and gross injustice., the Court found the detriment resulting from reliance had not been proved. However, the circumstances of this case differ, particularly regarding the specificity of the Governor's announcement and the individual impact on Doyle’s Tavern.
VI. Conclusion
Though the State made a “promise” to reopen July 1
st
, the COVID-19 virus was spreading, and public safety was the top priority. Doyle’s Tavern cannot claim detrimental reliance claim because his grounds do not fulfill the qualifications the Supreme Court set forth with the Gold Finger's ruling. The State’s rescinding of the prior order would not be seen as a detrimental reliance because the repeal was done with the public’s best interest in mind.
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