Harmon v. State
62 A.3d 1198
Del.2013Background
- Delaware Harness Racing Commission suspended Harmon after allegations of altering a judging sheet.
- Wayne, Administrator of Racing, conveyed a promised reinstatement to Harmon following Harmon's acquittal.
- Commission later decided not to reinstate Harmon and informed him by letter (Nov 18, 2004).
- Harmon filed suit (Jan 2007) asserting promissory estoppel among other claims; trial court later granted JMOL/new trial.
- Jury awarded Harmon $102,273 on promissory estoppel; appellate court reversed JMOL/new trial and reinstated verdict.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can the state be held liable on promissory estoppel? | Keating exception applies; state employment context permits estoppel. | General rule bars estoppel against governmental functions. | Yes; promissory estoppel applies. |
| Was there sufficient evidence of a promise by the Commission? | Wayne's testimony and Commission response create an implied promise. | No actual authority or formal vote to promise reinstatement. | Sufficient evidence of a promise. |
| Did Harmon reasonably rely and suffer detriment? | Harmon would seek other work but for reinstatement; detriment shown. | Reliance not adequately proven or damages not recoverable as reliance. | Reliance and detriment established. |
| Are reliance damages appropriate and supported by the record? | Damages measured by lost wages during suspension are proper. | Damages limited or not properly framed as reliance damages. | Damages proper and supported. |
Key Cases Cited
- Lord v. Souder, 748 A.2d 393 (Del. 2000) (promissory estoppel exceptions for state actions in employment)
- McCoy v. State, 277 A.2d 675 (Del. 1971) (sovereign immunity safeguards and equitable exceptions)