Weavertown Transport Leasing, Inc. v. Moran

834 A.2d 1169 · Superior Court of Pennsylvania · 2003

Facts

Moran, an employee, orally agreed to transfer his Pittsburgh Steelers season ticket licenses to his employer, Weavertown, for client entertainment. Weavertown paid the license fees and season ticket costs directly to the Stadium Building Fund and the Steelers. After Moran resigned, he refused to transfer the licenses, claiming no binding contract existed.

Issue

Did Weavertown's payments to the Steelers and Stadium Building Fund constitute valid consideration for Moran's promise to transfer the season ticket licenses, or did promissory estoppel apply to enforce the oral agreement?

Holding

No, the payments did not constitute consideration because the Steelers and SBF were merely incidental beneficiaries, and Weavertown had no direct obligation to them. The court also found that promissory estoppel did not apply as Weavertown did not forgo a definite and substantial opportunity in reliance on Moran's promise.

Rule

Consideration requires a bargained-for exchange where the detriment incurred by the promisee is the "quid pro quo" for the promisor's promise. Payments to an incidental third-party beneficiary, who has no right to enforce the contract between the primary parties, do not constitute valid consideration. Promissory estoppel applies only when a promise induces definite and substantial action or forbearance, and injustice can only be avoided by enforcement.

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Case brief last reviewed 2026-04-18. Prepared by CaseReader from the published opinion.