United States First Circuit

Summary judgment in favor of defendant in an action arising out of failed negotiations between the parties over the purchase of oil containment boom from plaintiff, following the aftermath of the Deepwater Horizon oil spill of 2010, is affirmed, where: 1) plaintiff does not identify specific evidence in the record showing that any of defendant's statements were false at the time they were made; 2) no exception to the Statute of Frauds exists; 3) the district court correctly concluded that plaintiff cannot prevail under either an unjust enrichment or quantum meruit theory; and 4) plaintiff's promissory estoppel claim fails as a matter of law.

Appellate Information

• Decided 06/11/2014
• Published 06/11/2014

Judges

• STAHL

Court

• United States First Circuit

Counsel