Quake Construction, Inc. v. American Airlines, Inc.
Illinois Supreme Court
565 N.E.2d 990 (1990)
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.
Whether a letter of intent to enter into a contract is enforceable if the parties intended the letter to be contractually binding.