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A consulting firm emailed a specialist, "We will hire you for our Denver project starting July 1. Move by then and we will cover your relocation expenses." The specialist accepted, declined another project, paid to break his apartment lease, and moved to Denver. One week before July 1, the firm canceled the project and refused to reimburse him. The firm argues that the specialist gave no consideration because he had not yet performed consulting work.
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The consultant can recover only if the firm intended to deceive him when it made the promise. The consultant cannot recover because moving expenses are never reasonable reliance. The consultant cannot recover because promissory estoppel is unavailable whenever consideration is absent. The consultant may recover under promissory estoppel if the firm's promise reasonably induced substantial reliance and enforcement is necessary to avoid injustice.

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