Goldblatt Bros., Inc. v. Addison Green Meadows, Inc.
Illinois Court of Appeals
290 N.E.2d 715 (1972)
Goldblatt (plaintiff) leased a store in a shopping center Addison (defendant) was developing, under a lease requiring Addison to pave the entire surrounding area for parking, create at least 1,000 spaces, and connect a rear driveway to a nearby road. Addison paved only the front lot (yielding 732 spaces, which proved consistently sufficient), left large rear areas unpaved, and never completed the driveway connection to the road. Goldblatt sued for specific performance to complete the improvements as shown in the lease's map; the trial court found Addison had substantially performed and ruled for Addison.
Whether a court may order specific performance of a construction agreement that the defendant has not substantially performed.