Quake Construction, Inc. v. American Airlines, Inc.
Illinois Supreme Court
565 N.E.2d 990 (1990)
American Airlines, Inc. (American) (defendant) hired Jones Brothers Construction Corporation (Jones) (defendant) to handle construction contracts for the expansion of American’s facilities at O’Hare International Airport. Jones sent Quake Construction, Inc. (Quake) an invitation to bid on the project. Quake submitted its bid. Jones orally informed Quake that it would be awarded the contract. Jones wanted Quake to provide license numbers of its subcontractors, but Quake informed Jones that it could not until it had entered into a formal arrangement. In order to induce the subcontractors to provide their license numbers, Jones provided Quake with a letter of intent. This letter included language indicated that Quake had been awarded the contract, that American was authorizing the work, and that work would begin in approximately four to 11 days after the date of the letter. The letter also provided a cancellation clause, which provided that Jones could cancel the letter of intent if the parties could not agree on a fully executed agreement. Jones and Quake entered into negotiations for a written form contract. At a preconstruction meeting, Jones announced that Quake would be the general contractor for the project. American informed Quake that same day, however, that its involvement with the project was terminated. Quake filed suit. American and Jones filed a motion to dismiss. The trial court granted the motion to dismiss, finding that Jones lawfully terminated the contract under the cancellation clause. Quake appealed. The appellate court found the letter of intent too ambiguous as to the parties’ intent to be bound by it. American and Jones appealed to the Illinois Supreme Court.
Rule of Law
Holding and Reasoning (Calvo, J.)
Concurrence (Stamos, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 168,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 13,800 briefs, keyed to 187 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.