Reliance Interest

Case Examples

• A party’s reliance must be reasonable: Although reliance interest is mainly applied to entities reacting to changes in government policy, it can also be used to private individuals and companies as an element of promissory estoppel, so long as the reliance is reasonable. See Weinstein v. Meritor, Inc., 845 F. App'x 686, 687 (9th Cir. 2021). However, the party seeking to assert a reliance interest must provide evidence that its reliance was reasonable. Id.
• Immigration: In Dep't of Homeland Sec. v. Regents of the Univ. of California, 140 S. Ct. 1891, 1896, 207 L. Ed. 2d 353 (2020), the colleges argued that they had relied upon the Trump Administration's guidelines regarding Dreamer Act college-age children for enrollment purposes. They claimed that when the administration changed its policies on DACA status, it created a reliance interest for the universities, and the universities could sue the administration for any lost revenue. Id . The Supreme Court disagreed and found that the administration was within its rights to change the policy and the universities had not established a reliance interest. Id.
• Healthcare: In MediNatura, Inc. v. Food & Drug Admin., 998 F.3d 931 (D.C. Cir. 2021), a drug importer sued the FDA for changing its policies regarding fee exceptions on the import of certain drugs, which hurt the importer’s profits as they relied on the drugs being exempted. The court disagreed, stating that the importer failed to prove the reliance was reasonable. Id.
• Gambling: A party cannot claim a reliance interest if the harm is temporary. In Scotts Valley Band of Pomo Indians v. Burgum, No. 1:25-CV-00958 (TNM), 2025 WL 3034885, at *1 (D.D.C. Oct. 30, 2025), a Native American tribe sued the federal government for temporarily suspending the tribe’s gambling license, claiming the tribe relied on the money to function. The Court stated that the tribe had not demonstrated a reliance interest, as the harm was of short duration. Id .