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Quake Construction, Inc. v. American Airlines, Inc.

Illinois Supreme Court

565 N.E.2d 990 (1990)

Relevant factsFree

After Jones Brothers Construction (defendant), acting for American Airlines (defendant), sent Quake Construction (plaintiff) a letter of intent stating Quake had been awarded a contract and specifying a start date, but also including a cancellation clause and repeated references to a still-to-be-executed formal contract, American terminated Quake's involvement the same day Jones announced Quake as general contractor at a preconstruction meeting. The trial court dismissed Quake's suit, finding the cancellation clause allowed lawful termination, but the appellate court found the letter ambiguous as to binding intent and reversed.

IssueFree

Whether a letter of intent to enter into a contract is enforceable if the parties intended the letter to be contractually binding.

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