John A. Martens, Respondents v. Minnesota Mining & Manufacturing Company, Petitioner, Appellant

Summary

The court held that the employees' allegations concerning 3M's dual-ladder program failed to state claims for breach of unilateral contract, promissory estoppel, or fraudulent misrepresentation. The program materials and oral statements expressed general, performance-dependent policies rather than sufficiently definite contractual offers or promises, and the fraud allegations did not specifically identify knowingly false representations of fact. The court reversed the court of appeals and remanded for dismissal of the complaint with prejudice. Justice Anderson and Justice Gilbert separately disagreed that the contract and promissory-estoppel claims should be dismissed at the pleading stage, and Justice Gilbert also disagreed as to fraud.