## Facts

- In January 1991, John Reeves owned and operated a popular local tourist attraction near Fairbanks, Alaska.
- Reeves met with Keith Burke, Alyeska Pipeline Service Company’s local manager in Fairbanks, to discuss a proposed visitor center aimed at tourists visiting the nearby Trans-Alaska Pipeline.
- At Burke’s request, Reeves sketched and explained his visitor-center idea, including locating the center on Alyeska’s land.
- Reeves proposed that Alyeska lease the land to him for 20 years and, in exchange, receive a percentage of the visitor center’s admission-fee and gift-shop revenue.
- Burke did not know that Alyeska had received and rejected a similar visitor-center proposal in 1987.
- Reeves alleged that Burke agreed to keep the proposal confidential, told Reeves that the parties “had a deal,” and said he would have the necessary contracts prepared so the center could open in time for the 1991 tourist season.
- Over the next several months, Burke allegedly continued to encourage Reeves’s expectation that the deal would go forward.
- In August 1991, Alyeska opened its own visitor center, which was highly successful.
- Reeves sued Alyeska asserting theories including express contract, implied contract, and quasi-contract (unjust enrichment) based on Alyeska’s alleged use of Reeves’s proposal.
- The trial court granted summary judgment to Alyeska after concluding Reeves had not shown that his visitor-center idea was novel or original.
- Reeves appealed to the Alaska Supreme Court.

## Issues

1. Whether a plaintiff’s failure to show novelty or originality of an idea bars claims framed as express contract or implied-in-fact contract based on an alleged promise of confidentiality and/or a promise to proceed with a deal.
2. Whether the summary-judgment record raised genuine disputes of material fact about the formation and terms of an express or implied-in-fact agreement concerning Reeves’s visitor-center proposal.
3. Whether Reeves could proceed on a quasi-contract (unjust enrichment) theory for Alyeska’s use of the idea in the absence of an enforceable agreement, despite the trial court’s novelty finding.

## Decision

- The Alaska Supreme Court held that lack of novelty or originality is not, by itself, a complete defense to contract-based claims arising from the disclosure of an idea.
- The court concluded Reeves presented evidence that could support an express agreement (including confidentiality and an understanding that a deal existed) and/or an implied-in-fact contract, creating triable fact questions that made summary judgment improper on those claims.
- The court therefore reversed the grant of summary judgment in part and remanded for further proceedings on Reeves’s contract theories.
- To the extent Reeves sought recovery without proving an agreement (i.e., through quasi-contract), the court left in place the limits that apply when a plaintiff attempts to recover for use of an idea as such, rather than for breach of a promise.

## Legal Principles

- Claims based on an alleged express promise or implied-in-fact agreement arising from an idea submission are governed by contract principles; they do not automatically fail merely because the idea is not new.
- A promise of confidentiality and/or a promise to proceed with a transaction may supply the basis for enforceable contractual duties if the factfinder concludes the parties intended to be bound.
- Summary judgment is inappropriate where reasonable factfinders could differ on whether the parties formed an agreement, what was promised, and whether the recipient’s later conduct breached those obligations.
- Where a plaintiff seeks payment for use of an idea without proving an enforceable promise, courts may treat the claim more like “idea protection,” where novelty/originality can matter to whether the defendant received a cognizable benefit for which restitution is due.

## Conclusion

Reeves v. Alyeska Pipeline Service Co. holds that the absence of novelty in an idea does not automatically defeat claims that rest on alleged contractual promises made during and after the idea’s disclosure; because Reeves produced evidence from which a jury could find an express or implied-in-fact agreement tied to confidentiality and moving forward with the visitor-center deal, the Alaska Supreme Court reversed summary judgment in part and remanded for further proceedings on those contract-based claims.


Reeves v. Alyeska Pipeline Service Co., 926 P.2d 1130 (1996)