Cohen v. Cowles Media (1992)

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Cohen v. Cowles Media (1992)
Court Minnesota Supreme Court
Citation 479 N.W.2d 387
Date decided January 24, 1992
Related Cohen v. Cowles Media (1990)
Cohen v. Cowles Media (1991)


Dan Cohen (born 1936) was active in the Republican 1982 campaign of Wheelock Whitney Jr. (1926 - 2016) for governorship in the state of Minnesota.

Cohen had documents regarding the criminal history of Marlene Johnson (born 1946 - ) , the candidate for the Lieutenant Governor of Minnesota. He gave the documents to 2 newspapers provided that they would keep his identity confidential.

The editors of the newspapers published's Cohen's involvement in finding the documents. As a result, Cohen's employer fired him.

SCOTUS remands Cohen v. Cowles Media (1991) to the state of Minnesota which becomes this 1992 case.

Procedural History

Cohen sued Cowles Media Co. for fraudulent mis-representation & breach of contract.

The Minnesota trial court awarded damages to Cohen.


Can promissory estoppel be used to award damages to a confidential source injured by a newspaper's broken promise of anonymity?


Yes. If a source (Mr. Cohen) acts in reliance on the press's promise of confidentiality & is thereby injured, the court can award damages if that's the way to remedy the injustice.

The trial jury's award of $200,000 is reasonable & reinstated.


The promisee (Cohen) has suffered harm at his job as a result of relying on the newspapers' promise to grant him anonymity.


The newspaper editors published Cohen's name even though the reporters had made & intended to keep Cohen's name confidential.

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