## Facts

- Maria D’Ulisse-Cupo was a nontenured Spanish and Italian teacher employed under a fixed-term contract ending in June 1983.
- In spring 1983, the principal made statements suggesting she would be rehired, including that “everything looked fine” for rehire and she should continue planning an exchange program.
- At an April 1983 faculty meeting, the principal stated that teachers who had not received written notice about next year’s status should view things as the same as the prior year; she received no written notice.
- The principal later sent a letter to students and parents about an Italy trip planned “next year,” which she understood as confirming continued employment.
- On May 27, 1983, the principal informed her she would not be rehired due to staff cutbacks from low enrollment.
- She alleged additional assurances that the school would try to find another position, but she was not placed and was not used for substitute openings.
- She alleged reliance by continuing trip planning and not seeking other employment, causing economic loss.

## Issues

1. Whether the alleged statements and letter were sufficiently clear, definite, and promissory to support contractual liability for reemployment (including a promissory-estoppel-type theory).
2. Whether the complaint stated a claim for negligent misrepresentation based on employment-related assurances and resulting reliance losses.

## Decision

- The Supreme Court held the alleged assurances were too indefinite and nonpromissory to create an enforceable commitment to rehire; the contract-related counts were properly stricken.
- The Court held the complaint adequately alleged negligent misrepresentation; that count should not have been stricken.
- The judgment was affirmed in part and reversed in part, and the case was remanded for further proceedings limited to the negligent-misrepresentation claim.

## Legal Principles

- On a motion to strike, the court accepts well-pleaded facts and necessary implications as true and construes allegations favorably to the pleader.
- Contractual liability for a future employment commitment requires a promise that is sufficiently definite to determine meaning and to fix the parties’ legal obligations; statements of expectation, intention, or informal reassurance are not enough.
- Promissory estoppel requires a clear and definite promise and reasonable reliance; an indefinite or equivocal assurance cannot satisfy the promise element.
- Negligent misrepresentation may arise when, in the course of business, a party supplies false information for another’s guidance and fails to exercise reasonable care or competence in obtaining or communicating it, causing justifiable reliance and pecuniary loss.
- A pleading that alleges a party “negligently misrepresented” information can be sufficient to imply lack of reasonable care, even without reciting that phrase verbatim.

## Conclusion

The court rejected contract and promissory-estoppel theories because the alleged rehire assurances were not definite promises, but allowed the teacher to proceed on a negligent-misrepresentation claim based on allegedly careless employment-related assurances and reliance-based economic harm.


D'Ulisse-Cupo v. Bd. of Dirs. of Notre Dame High Sch., 202 Conn. 206, 520 A.2d 217 (Conn. 1987)