Pavel Enterprises, Inc. v. A. S. Johnson Company, Inc.
Court of Appeals of Maryland
342 Md. 143, 674 A.2d 521 (1996)
General contractor Pavel (plaintiff) used subcontractor Johnson's (defendant's) low bid in calculating its own bid to NIH, but Pavel initially came in second and was not immediately awarded the contract; only later was Pavel awarded the project, at which point it notified Johnson of selection, but Johnson claimed a bidding error and withdrew, forcing Pavel to hire a substitute subcontractor for $32,000 more. Pavel sued to recover that difference, and the trial court found no traditional contract was formed and no detrimental reliance established; Pavel appealed.
Whether, where the relationship between a general contractor and a bidding subcontractor does not satisfy traditional bilateral contract requirements, a subcontractor's promise may still create an enforceable obligation if it made a clear and definite promise that reasonably induced detrimental action by the general contractor.