Forman v. Benson
Illinois Appellate Court, Second District
446 N.E.2d 535 (1983)
Forman (plaintiff) offered to buy real property from Benson (defendant) for $125,000 payable over ten years, with the deal conditioned on "seller's approving buyer's credit report" -- a term added specifically at Forman's realtor's suggestion to ease Benson's stated concerns about Forman's creditworthiness. After signing and receiving the credit report, Benson engaged in further negotiations in which he raised the possibility of a higher purchase price before ultimately rejecting Forman's credit outright. Forman sued for specific performance; at trial a loan officer testified Forman's credit was generally excellent, and the trial court, applying a reasonableness standard, found Benson had unreasonably rejected Forman's credit and ordered specific performance.
Whether a satisfaction clause included to induce a party to sign an agreement is governed by a standard of reasonableness.