LEGAL QUESTION (Shorthand phrasing of legal issue):

Does a business owner have standing in a detrimental reliance action against the State if they rely on a public statement by the State's Governor prematurely allowing businesses to partially reopen during an unprecedented nationwide health crisis?

Section 470 of the Public Health Service Act (64 Olympus Code 541):

The Olympus Secretary of Health and Human Services is authorized to take measures to prevent the entry and spread of communicable diseases from foreign countries into Olympus and between states.Further, the states shall have police power functions to protect the health, safety, and welfare of persons within their borders. To control the spread of disease within their borders, states may enact laws to enforce the use of isolation and quarantine.

State Code Art. 2 1423.Cause defined; detrimental reliance

A party may be obligated by a promise when he knew or should have known that the promise would induce the other party to rely on it to his detriment and the other party was reasonable in so relying. Recovery may be limited to the expenses incurred or the damages suffered as a result of the promisee's reliance on the promise. Reliance on a gratuitous promise made without required formalities is not reasonable. (Note, Doyle's is the promisee)

"A party may be obligated by a promise when he knew or should have known that the promise would induce the other party to rely on it to his detriment"

1. How can your office argue this on behalf of your client, John Doyle?
2. How will the opposition argue it?