Ryan v. Warren Township High School District No. 121

510 N.E.2d 911 (1987)

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Ryan v. Warren Township High School District No. 121

Illinois Appellate Court
510 N.E.2d 911 (1987)

EL

Facts

The superintendent of a school district hired Keith Ryan (plaintiff), a public relations manager, as a consultant to help manage community opposition to district plans to raze a school that had been destroyed by a fire. Though state statutes required a public meeting before authorizing an expenditure for consultant-services contracts, the superintendent hired Ryan through an oral agreement. Ryan’s services included working with the school board and conducting meetings involving board members, helping to address public concern about the razing of the school. After performing some work, Ryan submitted a partial bill for his services. The school district (defendant) paid the bill. When Ryan concluded his services, he submitted a final bill, which the district refused to pay, contending that Ryan’s contract was unauthorized and, therefore, void. Ryan sued the school district in state court, seeking payment for his services. The state trial court found in favor of Ryan, holding that though the contract was not the result of the proper contracting process, equities required its enforcement because the school district had the power to enter into the contract and the board members were well aware of the work Ryan was performing for the district. The school district appealed to the state appellate court.

Rule of Law

Issue

Holding and Reasoning (Woodward, J.)

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