Equitable Estoppel in the Virgin Islands
In the Virgin Islands, equitable estoppel requires an asserting party to demonstrate that:
(1) the party to be estopped made a material misrepresentation;
(2) that induced reasonable reliance by the asserting party;
(3) resulted in the asserting party's detriment. See Joseph v. Inter-Ocean Ins. Agency, Inc., 59 V.I. 820, 837-38 (V.I. 2013).
In applying this doctrine, particularly in the context of real property, the Court proceed with great caution.
Huggins v. Castle Estates, Inc., 36 N.Y.2d 427, 330 N.E.2d 48, 53, 369 N.Y.S.2d 80 (N.Y. 1975) ("As far as the application of the doctrine of equitable estoppel is concerned we reiterate the rule ... that it should be applied with great caution when dealing with realty." );
Martin v. Cockrell, 335 S.W.3d 229, 237 (Tex. App. 2010) ("The gravity of a judicial means of acquiring an interest in land of another solely by parol requires that equitable estoppel be strictly applied; and the estoppel should be certain, precise and clear.");
Wilhelm v. Beyersdorf, 100 Wn. App. 836, 999 P.2d 54, 62 (Wash. Ct. App. 2000) ("Equitable estoppel is not favored." (citing Robinson v. City of Seattle, 119 Wn.2d 34, 830 P.2d 318, 345 (Wash. 1992))).