United Steelworkers Of America, Local

1330, et al. v. UNITED STATES STEEL CORPORATION 492 F. Supp. 1 (1980)

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Nature of the Case

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Facts

D decided to close its plants in the Mahoning Valley. Ps asked this Court for injunctive relief to keep the plants operating and their jobs intact. D answered that lack of profitability forced it to close and that it had a right to make this management decision, and the issues were thereby joined. On December 21, 1979, Ps filed this action and asked for a temporary restraining order. Ps' amended complaint suggests four theories in support of injunctive relief: breach of contract, promissory estoppel, violation of anti-trust statutes, and property rights. The breach of contract and detrimental reliance claims are based on a series of communications by employees of D to the workers at the Mahoning Valley plants. Ps allege these communications constitute a promise by the company to keep the mills operating if and so long as the workers made the mills profitable. The contract must be either unilateral or bilateral that is, parties must either exchange a promise for a promise or a promise for an act. Ps' allegations can be simplified to this: the company promised to keep the plants operational as long as they remained profitable, and the workers did in fact make the plants profitable. Ps never allege in the Complaint or show in the evidence that the workers, either individually or through their union, promised the company that they would make the plants profitable. Therefore, the contract must be of the unilateral, promise-exchanged-for-an-act, variety.