Clinton Growers v. Pilgrim's Pride Corp. (In re Pilgrim's Pride Corp.)
- Summarized by John Jones , J. R. Jones Law PLLC
- 11 years 10 months ago
- Citation:
- Case No. 12-10063 (5th Cir. January 31, 2013)
- Tag(s):
-
- Ruling:
- AFFIRMED bankruptcy court's grant of summary judgment for Pilgrim's Pride Corporation ("PPC") on the ground that written contracts between PPC and Clinton Growers barred the alleged oral promises of a contract for the long haul and promissory estoppel claim under the "contract bar" doctrine. The Fifth Circuit held that promissory estoppel applies only when the elements of a contract cannot be shown to exist. Under the "contract bar" doctrine, a party alleging promissory estoppel can succeed only by showing that the written contract does not cover the subject matter underlying the promissory estoppel claim.
- Procedural context:
- PPC filed for summary judgment on the Clinton Growers' claims under two theories: 1. the law of the case because the District Court for the Northern District of Texas had rejected similar claims in City of Clinton v. Pilgrims Pride Corp., 654 F.Supp.2d 536, 544-45 (N.D. Tx. 2009); and 2. the contracts barred the promissory estoppel claims because both the contracts and the promises covered the same subject matter. The bankruptcy court granted the summary judgment and the district court affirmed as to the granting of the summary judgment on the contract bar doctrine alone finding that the contracts barred the promissory estoppel claims because they covered the same subject matter as PPC's oral representations.
- Facts:
- Various growers from Clinton, Arkansas (the "Clinton Growers") entered into contracts with PPC to supply PPC's Clinton plant with chickens. The contracts detailed the compensation to be paid, contained a merger clause, and stated that the agreements were to continue on a "flock to flock basis." Citing economic stress caused by the increase in the price of chicken feed and the falling prices for chicken, PPC terminated the contracts in 2008 and PPC subsequently filed for bankruptcy. The Clinton growers brought promissory estoppel claims against PPC when it filed for bankruptcy based on claims that PPC assured the Clinton growers that PPC was in this for the long haul and that the growers would receive chickens as long as they met PPC's specifications. PPC also assured the growers that they would more than cover the costs of the buildings and raising the chickens which could cost approximately $150,000 per chicken house.
- Judge(s):
- DeMoss, Southwick, and Higginson, Circuit Judges
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