Occasion: William F. Langer (plaintiff) retired from Superior Steel (defendant) after many years of service. Superior Steel sent Langer a letter that promised $100 per month for life as long as he did not work for a competitor. For context, $100 in 1932 is around $2,300 in 2025. Superior Steel was willing to pay this much because Langer wasn’t a factory worker; he had been a superintendent for 33 years. His role carried significant responsibility, so the pension reflected his seniority. Langer complied with this condition and did not seek employment under a competitor. After four years, however, Superior Steel stopped the payments. Langer, in reaction, sued Superior Steel in order to enforce payments. 

 

Legal Issue: Was the company’s promise to pay $100 per month a gratuitous promise (unenforceable) or a contract supported by consideration (enforceable)?

 

Holding: The Pennsylvania Superior Court held that the promise was enforceable and Superior Steel was held liable to continue paying. 

 

Reasoning: The court argued that consideration did exist as Langer gave up his right to work for competitors and Superior Steel benefited by protecting its business interests. This case reinforces that consideration can be found in forbearance (giving up a legal right). 

 

Case File: 

https://www.courtlistener.com/opinion/4088899/langer-v-superior-steel-corp/