Wil-Fred's, Inc. v. Metropolitan Sanitary District

The Metropolitan Sanitary District (defendant) solicited bids for water-plant rehabilitation, and Wil-Fred's (plaintiff) submitted the lowest bid, $235,000 below the next lowest, based on a subcontractor bid from the experienced firm Ciaglo, backed by a $100,000 deposit. Ciaglo had mistakenly believed standard construction equipment could drive over the new plastic pipe to spread filter material, an error caused by the District's own specifications; other contractors and the manufacturer told Ciaglo this was wrong, and correcting it would cost $150,000 more than budgeted. Before the District awarded the contract, Wil-Fred verified the mistake and tried to withdraw its bid and reclaim its deposit; the District refused both, and Wil-Fred sued and won rescission and return of its deposit at trial, prompting the District's appeal.

Whether a contract, or in this context a bid, may be rescinded due to a unilateral mistake by the bidder or its subcontractor.