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Langer v. Superior Steel Corp. | 161 A. 571 (1932)

All enforceable contracts must be supported by adequate consideration. A promise that lacks consideration is known as a gratuitous promise and doesn’t give rise to an enforceable contract. In Langer versus Superior Steel Corporation, we explore how courts distinguish between gratuitous promises and enforceable contracts.

William Langer was the superintendent of the annealing department at Superior Steel Corporation. When Langer decided to retire, the president of Superior Steel wrote Langer a letter thanking him for his dedicated service to the company. In the letter, Superior Steel also agreed to pay Langer a one-hundred-dollar-per-month pension for the rest of his life so long as he didn’t go to work for a competitor. Langer didn’t go to work for a competitor, and Superior Steel paid Langer his monthly pension for approximately four years. Superior Steel then notified Langer that it wasn’t going to continue paying him.

Langer sued Superior Steel in Pennsylvania state court for breach of contract. Superior Steel argued that its letter was merely a gratuitous promise, not an enforceable contract. The trial court agreed and entered judgment in favor of Superior Steel. Langer appealed to the Pennsylvania Superior Court.

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