Branco Enterprises, Inc. v. Delta Roofing, Inc.
Missouri Court of Appeals
886 S.W.2d 157 (1994)
Branco (plaintiff), preparing an overall project bid, called subcontractor Delta (defendant) to confirm it could rely on Delta's low roofing bid, and Delta said yes. Branco won the overall project and signed its contract, but two months later, after work had started, Delta backed out of the roofing job. Branco sued for breach; the trial court found the parties had a contract and that Branco's reliance on Delta's bid was reasonable, and Delta appealed, arguing no contract existed because no written subcontract was ever signed.
Whether, under promissory estoppel, a contract exists between a general contractor and a subcontractor when the contractor reasonably relies on the subcontractor's oral bid in submitting its overall project bid.