Firestone Financial LLC v. Meyer

Summary

The Seventh Circuit affirmed summary judgment for Firestone Financial in its action against John Meyer as guarantor of defaulted loans. The court held that Meyer could not establish any element of his promissory-estoppel defense and counterclaim under Massachusetts law, including an unambiguous promise, reasonable reliance, or damages. The court also rejected his challenge to the commercial reasonableness of Firestone’s collateral sale and dismissed a duplicative appeal.

Holdings

1. The second appeal was duplicative because Meyer raised no arguments concerning the post-judgment motion and did not need a second appeal to raise such arguments.
2. Summary judgment for Firestone was proper because no reasonable jury could find that Meyer satisfied any of the three elements of promissory estoppel: an unambiguous promise, reasonable reliance, and resulting damages.
3. Meyer failed to rebut the presumption that Firestone's disposition of the collateral was commercially reasonable.

Questions Presented

1. Whether the district court properly entered summary judgment against Meyer's promissory-estoppel defense and counterclaim under Massachusetts law.
2. Whether Meyer presented evidence of an unambiguous promise, reasonable reliance, and damages sufficient to create a triable issue on promissory estoppel.
3. Whether Meyer rebutted the presumption that Firestone's disposition of secured collateral was commercially reasonable.
4. Whether appeal 17-1712 was duplicative of appeal 17-1611.

Disposition

dismissed