Designer Direct, Inc. v. DeForest Redevelopment Authority
United States Court of Appeals for the Seventh Circuit
313 F.3d 1036 (2002)
The DeForest Redevelopment Authority (DRA) (defendant) breached its three-phase contract with architect Levin (plaintiff) by failing to provide a promised liaison, changing parcel sizes, and failing to build promised infrastructure improvements before Phase III (property sales and construction) could begin; Levin, having spent $490,000 on architectural, engineering, and design plans in preparation for Phase III before terminating the relationship due to DRA's failures, sued for breach and the district court awarded fees and earnest-money return but denied Levin's requested $490,000 in reliance damages.
Whether, in a suit for breach of contract, an injured party can seek damages for expenditures it made in preparation for performance of the contract.