ACE Capital Title Reinsurance Company (“ACE”) proposed a joint venture for insurance and reinsurance with Olympic Holding Company, L.L.C., (“Olympic”), but, before signing any agreements, ACE backed out of the venture, and Olympic brought suit. The trial court granted summary judgment for ACE on the breach-of-contract and breach-of-fiduciary-duty claims, but the appellate court reversed, finding that ACE should be equitably estopped from using the statute of frauds as an affirmative defense and that parties to an implied joint venture may incur fiduciary obligations. In reversing the appellate court’s judgment and remanding the action to the trial court, the Ohio Supreme Court held that: (1) the breach of oral promise to sign an agreement did not remove the statute of frauds’ signing requirement, and, thus, promissory estoppel may not be used to bar the statute of frauds; (2) the agreement was unenforceable; and (3) no fiduciary duties were imposed on the parties. Finally, the Ohio Supreme Court stated that Olympic’s claim for reliance damages, still pending in state court, was an adequate remedy to recover damages from relying on an allegedly false promise. Olympic Holding Co., L.L.C., v. ACE Ltd., No. 2009-2057 (Ohio May 7, 2009).