Double AA Builders, Ltd. v. Grand State Const. LLC
Court of Appeals of Arizona
114 P.3d 835 (2005)
Grand State Construction (defendant) faxed Double AA Builders (plaintiff) a bid to act as subcontractor on a job Double AA was bidding to general-contract. The bid spelled out the scope of work, price, a 30-day payment schedule, and said the price was good for 30 days. Double AA used that bid in its own bid to the project owner and won the contract. Within 30 days, Double AA mailed Grand State a subcontract, but Grand State refused to sign or perform. Double AA sued on promissory estoppel and got damages equal to the cost difference with a replacement subcontractor, but the trial court denied Double AA's request for attorney's fees under an Arizona contract-fee statute. Both sides appealed - Grand State the damages, Double AA the fee denial.
Whether a promise is binding under promissory estoppel when the promisor should reasonably have expected the promise to induce action, the promise did induce that action, and enforcing it is the only way to avoid injustice.