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Satcher v. Satcher, 351 S.C. 477, 570 S.E.2d 535

Facts

Chip Satcher lived with his grandparents after his parents separated. Following his grandfather's death, Chip claimed ownership of the residence and farmland based on various legal theories. The trial court found that Chip did not prove ownership under any of these theories, but the Court of Appeals found that he established entitlement to the residence based on promissory estoppel.

James H. Satcher, III (Chip) claims ownership of a farm and residence where he lived with his grandfather, James H. Satcher, Sr. (Grandfather), asserting theories of an oral gift, oral contract to devise, and promissory estoppel.

Issue

Did Chip Satcher prove his claim to the residence and farmland based on theories of oral gift, oral contract to devise, and promissory estoppel?

Did Chip Satcher prove his claim to the residence and farmland based on theories of oral gift, oral contract to devise, and promissory estoppel?

Rule

To prevail under promissory estoppel, a claimant must prove: (1) the presence of a promise unambiguous in its terms; (2) reasonable reliance upon the promise; (3) the reliance is expected and foreseeable by the promisor; and (4) the promisee must sustain injury in reliance on the promise.

To prevail under any of these theories and avoid the application of the Statute of Frauds, Chip must prove each element by clear, cogent, and convincing evidence.

Analysis

The court found that Chip provided clear and convincing evidence of an unambiguous promise from his grandfather regarding the residence, which he relied upon by moving in and caring for his grandfather. However, the court determined that Chip did not provide sufficient evidence of a specific promise regarding the farmland, leading to the conclusion that the requirements for promissory estoppel were not met for that property.

In reasonable reliance on that promise, Chip moved to the house and provided Grandfather with companionship and other services for more than twenty years.

Conclusion

The court affirmed the trial court's decision in part, granting Chip title to the residence and pond, but reversed the decision regarding the farmland, remanding for further proceedings consistent with its findings.

Accordingly, we affirm in part and reverse and remand in part.

Who won?

Chip Satcher prevailed in part, as the court found he had established entitlement to the residence and pond based on promissory estoppel due to his reliance on his grandfather's promise.

We find Chip established entitlement to a portion of Grandfather's property based on promissory estoppel but agree that Chip did not prevail as to the other claimed property.

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