A doctor at the Park Nicolett Clinic desired to eliminate his need to do night calls under a specific plan election that had been implemented in 1995. In 2004, he asked for this election, but agreed to delay his request for a year because several other doctors were tied up. When he did submit his claim in April of 2005, it was denied as the policy had been revoked. He continued for a period of time and then accepted the pay cut when health reasons prevailed. In 2009, he then sued for breach of contract and promissory estoppel. The lower court found that each time he was paid after the denial of his election, it started a new statute of limitations. However, the Supreme Court reversed.

The Supreme Court began its analysis by stating how important it was that unreasonable delays be avoided by requiring the filing of timely claims. The issue then is when did the cause of action accrue? The court determined the breach occurred when his request was denied in 2005. Promissory estoppel failed for the same reason. The court distinguished cases where there is failure to pay such things as a commission, as here each claim commission payment would be different depending on the employee’s performance. Therefore, the employer’s obligation to pay could not be ascertained until the sales period was complete, meaning each failure to pay was a separate violation. Hamann v. Park Nicollet (Minn. Sup. Ct. 2011).