ContractsProf Blog

Editor: Myanna Dellinger
University of South Dakota School of Law

Saturday, December 31, 2005

Today in History: Drennan v. Star Paving

Monte_vista_school On this date, December 31, 1958, the California Supreme Court rewrote every construction contract in the state when it issued Drennan v. Star Paving, 333 P.2d 757 (Cal. 1958).

In the case, contractor Drennan called Star Paving to get a quote to build the Monte Vista Elementary School in Lancaster, California (left).  Star did not say that its bid was irrevocable, and Drennan did not pay for an option.  After Drennan used Star's bid in his contract proposal, but before Drennan accepted the bid, Star notified him that its bid was mistaken and that it was withdrawn.

Justice Traynor, for the court, held that a subcontractor's bid on a construction job could not be revoked once the contractor had relied on it, even if it had not been accepted and even if no consideration had been paid for keeping the bid open.  (Photo:

[Frank Snyder]

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