Youngman v. Nevada Irr. Dist

In Youngman v. Nevada Irr. Dist. (1969) 70 Cal.2d 240, an employee sued after his employer denied a merit increase in pay. The employee alleged he had relied on the company's policy of granting annual increases in accepting employment with the water district, continuing to work for the water district, and in refraining from seeking employment elsewhere. The Supreme Court found the doctrine of promissory estoppel inapplicable because the employee had given consideration in exchange for the company's promise. "By remaining in his position and presumably rendering satisfactory service he performed his part of the bargain and rendered the consideration called for by the employment contract. There is no occasion, therefore, to rely upon the doctrine of promissory estoppel, which is necessary only to supply consideration for a promise when no actual consideration was given by the promisee." (Youngman v. Nevada Irr. Dist., supra, 70 Cal.2d 240, 250.)