Facts
- A decedent, during a prolonged illness, was visited multiple times by the synagogue’s rabbi.
- On several visits, in the presence of witnesses, the decedent orally promised to give the synagogue $25,000.
- The synagogue planned to convert a storage room into a library and intended to name it after the decedent.
- The promise was never put in writing.
- The synagogue allocated the anticipated $25,000 in its budget but did not begin construction or spend funds in reliance on the promise.
- The decedent died intestate in September 1985 and was survived by a spouse.
- The estate’s administrator did not pay the $25,000, and the synagogue sued to enforce the promise.
Issues
- Whether an oral promise to donate $25,000 to a religious congregation was an enforceable contract supported by consideration.
- Whether the congregation’s planning and budgeting for a library constituted sufficient reliance to enforce the promise under promissory estoppel.
Decision
- The Supreme Judicial Court affirmed summary judgment for the estate.
- The oral pledge was gratuitous and lacked consideration because there was no bargained-for exchange and no legal benefit to the promisor or detriment to the promisee.
- The proposed naming of a library after the decedent did not supply consideration because it was not shown to be requested or bargained for by the decedent.
- Promissory estoppel did not apply because the congregation showed no substantial, induced change of position; planning and budgeting without expenditures or other concrete action was insufficient.
Legal Principles
- An enforceable contract requires consideration: a legal benefit to the promisor or a detriment to the promisee arising from a bargained-for exchange; moral obligation alone is not enforceable.
- A charitable pledge may be enforceable if supported by consideration or if the charity materially changes position in reliance on the promise.
- Promissory estoppel requires action or forbearance induced by the promise and a substantial change in position; mere intent, planning, or internal budgeting without concrete reliance is inadequate.
Conclusion
An oral charitable pledge is not enforceable against an estate where the charity cannot show a bargained-for exchange or a substantial, promise-induced change of position beyond planning and budgeting.