Not Having Proper Teaching Certification After Already Accepting the Job

In Travers v. Cameron County School District, 117 Pa. Commw. 606, 544 A.2d 547 (Pa. Cmwlth. 1988), the school district hired James E. Travers (Travers) for a teaching position. Upon accepting the job, Travers moved from Ohio to Pennsylvania. After school started, the school district learned that Travers did not have the proper teaching certification. the school district informed Travers that he had until the beginning of the second semester to acquire the certification and that failure to do so would result in the cancellation of his contract. Because classes necessary to obtain certification were already underway, Travers was unable to obtain certification. Travers filed a complaint against the school district, alleging in part that the district, through its agents/employees, had assured him when it offered him the position that he was qualified for the position and had promised Travers that it would prepare and submit the requisite Pennsylvania certification application if Travers accepted the position. Travers alleged that the school district failed to do so, breaking its promise, that he relied on their promises and inducements and that he suffered irreparable financial harm, which was foreseeable to the school district. The trial court dismissed Travers' action for failure to state a cause of action. The court reversed, holding that the allegations and inferences were sufficient to state a cause of action based on promissory estoppel.