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Langer v. Superior Steel Corp.

(1932)

Superior Court of Pennsylvania - 161 A. 571, 105 Pa. Super. 579

tl;dr:

Former employer stops paying pension as promised. Employee's non-compete agreement is consideration for the pension.

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Case Summary

In a 1932 case called Langer v. Superior Steel Corp., the Pennsylvania Superior Court decided that if a retiring employee agrees not to work for a competitor, and the employer promises to pay them a pension, there is a valid contract with legal consideration. The case happened when an employee sued his former employer for not paying the promised pension. His employer argued there was no contract because the employee did not give any consideration.

The trial court sided with the employer, but on appeal, the decision was reversed. The court said there was a valid contract between the parties because consideration can be either a benefit for the person making the promise or a detriment to the person receiving it. The court found that the employee's promise not to work for a competitor was enough of a detriment to be considered consideration.

The court rejected the employer's argument that it did not get any benefit from the employee's promise, stating that a contract doesn't need to show actual benefit, as long as something was promised, done or given up by the person receiving the promise at the request of the person making it.

This case is significant because it helps define consideration in contract law and shows how courts look at consideration as a key part of a valid contract. It also highlights the importance of the parties' intentions rather than their subjective opinions on what is a benefit or a detriment.

ICRAIssue, Conclusion, Rule, Analysis for Langer v. Superior Steel Corp.

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Facts & HoldingLanger v. Superior Steel Corp. case brief facts & holding

Facts:When Langer (plaintiff) retired from Superior (defendant), Superior offered him...

Holding:Langer's agreement to forfeit the opportunity to work at Suerpior's...

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Langer v. Superior Steel Corp. | Case Brief DeepDive
Majority opinion, author: Baldrige, J.
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The plaintiff is seeking damages for breach of contract in a case of assumpsit. The defendant made monthly pension payments for four years but then stopped. The lower court ruled in favor of the defendant based on questions of law raised by them. The issue is whether the letter in question created a gratuitous promise or an enforceable contract. To determine if a contract was created, it must be based on a consideration, which is something of value given in exchange for a promise. The court below held that there was not enough consideration in the case because the plaintiff was not obligated to refrain from seeking other employment or continuing loyalty to the defendant. However, an agreement is not invalid for lack of consideration just because one party has an option while the other does not.

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