In Ricketts v. Scothorn 57 Neb. 51, 77 N.W. 365 (Neb. 1898), a grandfather told his granddaughter that she didn't need to work anymore and gave her a promissory note for $2k.  She immediately quit her job and remained jobless for over a year.  Then the grandfather died without giving her the $2k.  The Court reasoned that "the expenditure of money or assumption of liability by the donee on the faith of the promise is the true reason for the preclusion of the defendant, under the doctrine of estoppel.

• The grandfather had intentionally influenced the granddaughter to alter her position for the worse on faith of a note being paid when due.