Rick’s Original Philly Steaks, Inc. v. Reading Terminal Market Corporation, Case No. 08-0307 Court of Common Pleas of Philadelphia, Pennsylvania, February 20, 2008.
Pennsylvania does not recognize a cause of action for breach of a duty to negotiate contracts in good faith. Rick’s Original Philly Steaks had sued the Reading Terminal Market when the market failed to renew Rick’s lease so that a new Philly cheese steak vendor could take the same location. The claim was based on an alleged broken promise to renew the lease, but the Court found it not fraud to break a promise about the future. The only claim the Court allowed was based on the theory of promissory estoppel, since Rick’s had apparently remodeled the leasehold space in reliance upon the possibility that its lease would be renewed by the Reading Terminal Market