Cote v. Department of Human Services, 2003 ME 146

Summary

The Supreme Judicial Court of Maine affirmed summary judgment for the Department of Human Services on Linda Cote's claim that a Department employee's statement created an oral contract for adoption assistance. The court held that the statement that Cote would be eligible for assistance "at the going rate" was too indefinite to establish a prima facie case of breach of contract. The court therefore did not need to address the parol evidence rule, fraudulent inducement, or contract sovereign immunity.

Holdings

1. The statement did not create an oral contract because it did not sufficiently define the parties' liabilities, even assuming that the going rate differed from the amount Cote received.
2. Those issues did not need to be decided because Cote sought to enforce an alleged oral contract and failed to allege facts establishing a prima facie case for that contract.

Questions Presented

1. Whether the Department employee's statement that Cote would receive adoption assistance at the going rate was sufficiently definite to create an enforceable oral contract.
2. Whether it was necessary to resolve Cote's fraudulent-inducement argument or apply the parol evidence rule before determining whether she established a prima facie breach of an oral contract.
3. Whether summary judgment for the Department was proper.

Disposition

affirmed