## Facts

- Mark Hinkel worked for other employers when John Jacobs, Sataria’s owner, recruited him to join Sataria in 2005.
- Hinkel alleged Jacobs orally promised that if Sataria terminated him, Sataria would pay one year of salary and provide one year of health insurance, but the promise would not apply if Hinkel quit.
- Jacobs sent Hinkel a written, signed employment offer listing compensation, location, position, start date, vacation (undetermined), and health insurance start date; it contained no severance or post-termination benefits.
- Hinkel signed the written offer, left his prior employment, and began work for Sataria in September 2005.
- Hinkel claimed Jacobs reiterated the one-year severance-and-insurance promise in November and December 2005.
- Sataria terminated Hinkel on January 23, 2006; it paid six weeks of severance but did not provide one year of salary or insurance.
- Hinkel sued for breach of contract and promissory estoppel; the trial court granted Sataria summary judgment.

## Issues

1. Whether an alleged prior or contemporaneous oral promise of severance and insurance was enforceable when a signed written employment agreement omitted severance terms and was treated as fully integrated.
2. Whether alleged post-contract assurances of severance constituted an enforceable modification supported by new consideration.
3. Whether promissory estoppel could provide relief for the alleged severance promise despite the existence of an express written employment agreement.

## Decision

- The Indiana Court of Appeals affirmed summary judgment for Sataria.
- The court held the written employment offer was a completely integrated agreement that barred use of prior or contemporaneous oral severance promises under the parol evidence rule.
- The court held any alleged severance assurances made after execution were unenforceable modifications because they were not supported by additional consideration.
- The court rejected promissory estoppel because Hinkel did not show reliance-based detriment requiring enforcement to avoid injustice, and an express written contract governed the employment relationship.

## Legal Principles

- When a writing is treated as the final and complete expression of the parties’ agreement, the parol evidence rule precludes using prior or contemporaneous oral statements to add to or vary the written terms.
- A contract modification requires new or additional consideration; continued performance already owed under the original agreement generally does not supply such consideration.
- Promissory estoppel requires a promise, reasonable reliance, and a detriment such that enforcement is necessary to avoid injustice; it is not generally available to override an integrated written contract absent a sufficient equitable showing.

## Conclusion

The court enforced the written employment agreement as a complete integration, refused to add an oral severance term excluded from the writing, found no consideration for any later severance modification, and denied equitable relief because the claimed reliance injury did not justify promissory enforcement.


Hinkel v. Sataria Distribution & Packaging, Inc., 920 N.E.2d 766 (Ind. Ct. App. 2010)