Gail M. Norton v. Hoyt. No. 03-2281. No, not that Gail Norton. (This is a case of a spurned lover under Rhode Island law. So read on, if you care.) But there is adulterty.
Gail M. Norton, engaged in an adulterous relationship with decedent, Russell L. Hoyt, for twenty-three years. During the course of the relationship, Hoyt allegedly maintained that he would divorce his wife, marry Norton, and support Norton for the rest of her life. Following the end of the relationship, when it became apparent to Norton that Hoyt would not continue to support her and that the relationship could not be reconciled, Norton sued Hoyt, claiming promissory estoppel; (2) intentional infliction of emotional distress; the tort of outrage; fraud; and (5) breach of promise to marry.
Applying Rhode Island law, the court held that.
1) The promissorry estoppel claim fails because (a) her claim does not satisfy the conditions required to make out a claim of promissory estoppel, and (b) her claim sounds in palimony, which is a cause of action that has not been recognized in Rhode Island.
2) The IIED claim fails although Rhode Island has not determined whether IIED is available in intimate relations cases, she couldn’t get past summary judgment, because his conduct was just not that outrageous.
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