## Facts

- H. W. Lueddecke sent letters to Chevrolet-related companies claiming he had identified a design/location error in Chevrolet automobiles that caused vehicles to lean to one side after years of use.
- Lueddecke proposed to disclose the corrective measure only in exchange for compensation, asserting the fix would be inexpensive for the manufacturer but costly to owners if uncorrected.
- The companies responded that they did not enter agreements regarding inventions or ideas until sufficient information had been submitted for examination, inviting submission of complete details for evaluation without promising payment.
- Lueddecke replied with a general description of the alleged defect and suggested measures (e.g., relocating internal parts to balance weight or adding springs), but did not provide detailed plans or drawings.
- The companies then expressly declined to enter any agreement relating to Lueddecke’s suggestions.
- Lueddecke alleged that the companies later incorporated his suggestions into subsequent vehicle designs and sought recovery of the reasonable value of his idea on an implied contract theory.
- The trial court sustained demurrers to the petition; Lueddecke elected not to amend, and the action was dismissed.

## Issues

1. Whether an implied-in-fact contract to pay for an idea can be inferred from correspondence and alleged later use when the recipient expressly refused to enter any agreement concerning the idea before and after disclosure.
2. Whether the petition stated a legally sufficient claim for breach of an implied contract based on disclosure of an idea followed by alleged adoption of similar features.

## Decision

- The court affirmed the dismissal after demurrers were sustained.
- The court held that the pleaded correspondence and conduct did not support any express or implied promise by the companies to pay.
- The companies’ explicit refusal to enter any agreement negated any inference of an implied contract from later use of the idea.
- Even assuming the companies later used the suggestion, the petition did not state a cause of action for breach of an implied contract.

## Legal Principles

- An implied-in-fact contract requires facts showing a mutual understanding, inferred from conduct and communications, that compensation will be paid if the idea is used.
- No promise to pay will be implied where the recipient clearly disclaims any agreement or obligation to compensate before the idea is disclosed.
- Voluntary disclosure of an idea after notice that no commitment will be made does not create contractual liability merely because the recipient later uses a similar idea.
- On demurrer, even accepting allegations of later use as true, dismissal is proper if the pleaded facts do not show a legally cognizable promise or duty to pay.

## Conclusion

Because the companies expressly refused to contract and Lueddecke disclosed his idea despite that refusal, the court would not imply a promise to pay from the companies’ later alleged use of the suggestion, and the petition failed to state a claim for breach of an implied contract.


Lueddecke v. Chevrolet Motor Co., 70 F.2d 345 (8th Cir. 1934)