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Coley v. Lang | 339 So.2d 70 (1976)
Unfortunately, people break promises all the time. But when do the circumstances warrant a court to step in and force a party to make good on a promise? In the nineteen seventy-six Alabama case of Coley versus Lang, we examine this very question in the context of a stock-purchase arrangement.
William Coley and Robert Lang entered into discussions toward the end of August in nineteen seventy-two. The subject of the talks was Coley’s potential purchase of the I A S Corporation, in which Lang was a majority stockholder. Coley wished to purchase only the name and goodwill of the company to facilitate his bidding on government contracts.
On September first, during negotiations, both Coley and Lang signed a letter outlining several terms and conditions of the proposed sale. The letter also stated that it would be reduced to a, quote, “definitive agreement,” unquote, no later than September eighteenth.
In the interim, Coley registered with the government as an I A S Corporation representative and attended associated bid conferences.
On September eighteenth, Coley informed Lang that the sale would not work out within the contemplated timeframe because some government details had not yet been completed.
Lang sued Coley in trial court for breach of contract, requesting Coley’s specific performance to purchase the company stock for sixty thousand dollars, as outlined in the letter. The trial court denied Lang specific performance but did find Coley’s promise to be binding under the doctrine of promissory estoppel. The court awarded Lang seven thousand five hundred dollars in damages. Coley appealed.
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