## Facts

- Dr. David F. Michie served as an elected trustee on a Wyoming school district board from 1981 to December 1988.
- In 1984, the board asked whether trustees could participate in the district’s group health-insurance plan; counsel advised participation was permissible if each trustee paid the full premium.
- The superintendent informed the board that participation would not be limited to a trustee’s term of office, and the board voted to allow trustees to join the plan at their own expense.
- Relying on the board’s action and statements, Dr. Michie canceled his family’s private health-insurance policy and enrolled his family in the district plan effective December 1, 1984; another trustee also enrolled.
- In March 1989, a later board voted to disallow participation in the district insurance plan by all board members, past or present, and the district terminated the Michies’ coverage.
- The Michies sued, asserting promissory estoppel based on detrimental reliance; the trial court granted summary judgment for the board.

## Issues

1. Whether promissory estoppel may be used against a governmental body to enforce an alleged promise of continued participation in a public employer’s group health-insurance plan beyond the official’s term.
2. Whether public policy limiting a public board’s power to bind successor boards bars promissory estoppel even where reliance and detriment are shown.
3. Whether summary judgment was proper where the claim depended on enforcing an indefinite, forward-looking governmental commitment.

## Decision

- The Wyoming Supreme Court affirmed summary judgment for the board.
- The court held the Michies could not enforce continued insurance participation through promissory estoppel against the later board.
- The court concluded that the public-policy rule against one governing body binding its successors to extended-duration commitments defeated the claim as a matter of law, notwithstanding the alleged promise and reliance.

## Legal Principles

- Promissory estoppel is applied with caution against governmental entities and cannot compel a public body to take action beyond its lawful authority.
- A public governing board generally may not irrevocably bind successor boards in ways that restrict future policy-making discretion for an extended or indefinite period absent clear legal authorization.
- Reliance and detriment do not overcome the public-policy limitation that protects successor boards’ ability to change or terminate prior policy decisions involving ongoing public administration.

## Conclusion

Wyoming refused to impose promissory estoppel to preserve former trustees’ continued participation in a school district health plan because enforcing an indefinite promise would improperly bind successor boards and restrict future governmental discretion, making summary judgment for the board appropriate.


Michie v. Bd. of Trustees of Carbon Cnty. Sch. Dist. No. 1, 847 P.2d 1006 (Wyo. 1993)