## Facts

- Reverend Eugene Cochran served as pastor of Robinhood Lane Baptist Church (the Church) for many years, including from September 18, 1981 until his death on August 20, 1995.
- During Reverend Cochran’s service, the Church paid him a salary and provided additional benefits, including cell-phone and beeper services, lawn services, gas, and vehicle maintenance.
- Under an oral arrangement connected to Reverend Cochran’s pastoral service, the Church provided many of those benefits directly to his wife, Annie B. Cochran.
- Before he died, Reverend Cochran asked the Church’s deacons to provide for Annie if the Church was able.
- After his death, on September 3, 1995, the Church and Annie signed a written “Pastor’s Spouse Benefits” agreement.
- The agreement promised Annie $783.56 on the first and third Sunday of each month for 15 years (through September 5, 2010) and lawn-care services for her residence until she moved.
- The agreement stated that benefits would terminate if Annie died or remarried, with a minimum five-year period of payments if she remarried within five years of signing.
- The agreement also stated that it terminated the benefits Annie had been receiving under the prior oral arrangement connected to Reverend Cochran’s services as pastor.
- Shortly after the agreement was executed, the Church stopped making the promised payments.
- Annie sued the Church for breach of contract and declaratory relief, later adding a promissory-estoppel claim.
- The chancery court granted summary judgment to the Church, finding no consideration supported the written agreement and that promissory estoppel did not apply.
- Annie appealed, arguing consideration existed because she (1) continued attending the Church as “first lady,” (2) relinquished prior benefits under the oral arrangement, and (3) refrained from remarrying (including rejecting a marriage proposal) after signing the agreement.

## Issues

1. Whether the “Pastor’s Spouse Benefits” agreement was supported by legally sufficient consideration from Annie Cochran.
2. If not, whether the Church’s promise was nonetheless enforceable under promissory estoppel based on Annie’s claimed reliance.

## Decision

- The Tennessee Court of Appeals affirmed summary judgment for the Church.
- The court held the agreement was not supported by consideration because Annie’s asserted acts (continued attendance as “first lady,” loss of prior benefits, and remaining unmarried) were not shown to be bargained-for exchanges for the Church’s promise.
- The court held promissory estoppel did not apply to enforce the Church’s promise on these facts.

## Legal Principles

- An enforceable contract requires consideration: a bargained-for legal detriment to the promisee or legal benefit to the promisor; a promise motivated by generosity is not enforceable as a contract.
- Conduct offered as consideration must be the agreed price of the promise; continued association or attendance, without proof it was bargained for, does not supply consideration.
- Giving up a benefit is not consideration if the promisee had no independent enforceable right to keep receiving it; terminating pastor-related benefits after the pastor’s death does not by itself create a new bargained-for exchange with the spouse.
- A clause ending payments upon remarriage may function as a condition limiting a voluntary support promise rather than a bargained-for promise to remain unmarried.
- Promissory estoppel in Tennessee requires a clear and definite promise, reasonable and foreseeable reliance, and circumstances where enforcement is necessary to avoid injustice; it is applied narrowly and does not routinely replace consideration.

## Conclusion

The Court of Appeals treated the Church’s written commitment to support its late pastor’s widow as a voluntary support promise rather than a bargained-for contract, concluding Annie’s asserted attendance, relinquishment of prior benefits, and decision not to remarry did not constitute consideration, and it declined to enforce the promise through promissory estoppel, affirming summary judgment for the Church.


Cochran v. Robinhood Lane Baptist Church, 2005 WL 3527627 (2005)