CASE ANALYSIS: Derek A. ARDITO, et al., v. CITY OF PROVIDENCE, et al.

MGMT520 - Legal Political and Ethical Dimensions of Business

 Derek A. ARDITO, et al., (Plaintiffs) v. CITY OF PROVIDENCE, et al (Defendants).

U.S. District Court, District of Rhode Island

Facts

In 2001, the City of Providence (all defendants collectively referred to as "the City")

decided to begin hiring officers to fill existing vacancies in its Police Department ("the

Department") and additional vacancies that the City expected would result from anticipated

retirements. Only individuals who graduate from a training academy conducted by the City are

eligible to become Providence police officers. Accordingly, the City decided to conduct two

consecutive training academies, the 60th and 61st Police Academies. To be admitted, an

applicant had to pass a series of tests and be deemed qualified by members of the department

after an interview. The applicants judged most qualified were sent a letter informing them that

they had been selected to attend the academy if they successfully completed a medical checkup

and a psychological examination.

On October 15, the City of Providence sent letters to Ardito and 13 other candidates

stating that if the recipients successfully completed a medical checkup and a psychological exam,

they would be allowed to attend the 61st Police Academy. Academy training was the last step to

being hired onto the police force. The letters stated that they were “conditional offers of

employment.” A new police chief, Dean Esserman, had come in during the middle of the

selection process and determined that certain people sent the letter would not be offered a place

in the Academy, even though they had completed the exams. Ardito and the 13 others sued to

have the City stop holding the Academy unless they were admitted, alleging that the city

breached their contract.

 Procedure

Ardito and 13 other newly rejected applicants filed a suit in a federal district court against

the City of Providence, seeking a halt to the 61st Academy unless they were allowed to attend.

The plaintiffs alleged, among other things, that the city was in breach of its contract.

Issue

Was the letter a valid unilateral contract that was accepted by Ardito and the others when

they completed the medical and psychological exams?

Applicable laws

A unilateral contract, or one-sided contract as it is also called, is an agreement between

an interested, service-requesting party (the offeror) and a potential service-rendering party (the

offeree) to lawfully render a specified service for a fee.

In a unilateral contract, the party to perform the duty is free to decide whether they should render

the requested service or not, while the service-requesting party is bound to pay the agreed

amount of money once the duty is performed by the service-rendering party. Unilateral contracts

are deemed enforceable by contract law. However, there can't be legal issues until one party

claims to have rendered the requested service.

Since, with a unilateral contract, there can't be a contract breach until after the service-rendering

party has taken action, a lawsuit would mostly become necessary only when the service-

requesting party refuses to pay the agreed amount of money, claiming unsatisfactory service.
Therefore, determining a contract breach would depend on how clear or vague the terms of the

contract were and if the disputing party can prove that they satisfactorily rendered the requested

service.

Holding

The October 15 letter was a unilateral contract that was accepted by Ardito and others when they

completed their medical and psychological examinations. The court issued an injunction halting

the 61st Police Academy unless the plaintiffs were allowed to attend.

Reasoning

A valid contract requires that two parties mutually assent to the terms of the offer,

consideration be given, both parties have the contractual capacity to form a contract, and the

contract’s goal is a legal one. Mutual assent is present when the offeree accepts the terms given

by the offeror. In a unilateral contract, the offer is phrased so that the offeree accepts the offer

only by performing the actions required in the contract. The court ruled that the October 15 letter

was a perfect example of a unilateral contract because it was a "conditional offer of employment"

and the message that it conveyed was that the recipient would be admitted into the 61st Academy

if he successfully completed the medical and psychological examinations. Under the law, it

would be illegal for the City to require the candidates to undergo these exams unless it was

making a conditional offer of employment. The October 15 letter was much different from

notices sent to applicants by the City at prior stages of the selection process. Earlier notices

merely informed applicants that they had completed a step in the process and remained in good

standing, unlike the October 15 letters extending a conditional offer of admission. By completing
the exams, the candidates accepted the terms of the contract and gained admission into the

academy. Some of the plaintiffs quit their old jobs and turned down other job offers. Under the

doctrine of promissory estoppel, an offeror whose promise induces an offeree to act or forbear to

act is estopped from claiming the contract is invalid for lack of consideration. The City offered

several arguments, all of which the court rejected. One of these arguments was that the plaintiffs

have no right to employment; therefore, the city argued, there is no contract present. The court

said that this argument was not the point. The plaintiffs sought to enforce a contract that they

would be admitted into the Academy as long as they completed their mental and physical exams;

they did not seek to enforce a contract making them permanent Providence police officers.

References

Kubasek, N. K., Brennan, B. A., & Browne, M. N. (2017). The legal environment of business: A

critical thinking approach. Boston: Pearson.

Ardito v. City of Providence, 263 F. Supp. 2d 358 (D.R.I. 2003). (n.d.). Retrieved from

https://law.justia.com/cases/federal/district-courts/FSupp2/263/358/2505553/