Lectus, Inc. v. Rainier National Bank

We are asked to adopt Restatement (Second) of Contracts § 217A (Tent. Drafts Nos. 1-7, 1973) (hereafter § 217A) 1 and thus recognize promissory estoppel as a theory of recovery notwithstanding the statute of frauds, RCW 19.36.010. 2 We decline to do so at this time.

Lectus, Inc., petitioner herein, sued Rainier National Bank and Rainier Bancorporation, respondents, for breach of contract. At the opening of trial respondents made an extemporaneous motion based on the statute of frauds to exclude evidence of an alleged oral agreement. Treating the motion as one for summary judgment, the trial…