Southern California Acoustics Co., Inc. v. C.V. Holder, Inc.
Supreme Court of California
456 P.2d 975 (1969)
Southern California Acoustics (plaintiff), a subcontractor, submitted a bid to C.V. Holder (defendant), a general contractor bidding on a school district prime contract, but Holder never responded to or accepted Acoustics' bid; after Holder won the prime contract, a newspaper article listed Acoustics among Holder's subcontractors, leading Acoustics to assume its bid had been accepted and to refrain from bidding on other prime contracts. Holder later substituted a different subcontractor, and Acoustics, after an unsuccessful mandamus action against the school district, sued Holder for breach of contract or, alternatively, promissory estoppel.
Whether, for the doctrine of promissory estoppel to apply, there must first exist a promise that the promisor intended to induce action or forbearance of a definite and substantial character by the promisee.