This Note questions the North Carolina Court of Appeals decision in Home Electric Co. of Lenoir, Inc. v. Hall & Underdown Heating & Air Conditioning Co. This Note discusses sections 90 and 87(2) of the Restatement (Second) of Contracts and their corresponding comments and illustrations; the North Carolina Supreme Court decision in Wachovia Bank and Trust v. Rubish; and the rationale of the Fourth Circuit Court of Appeals in Allen M. Campbell Co. v. Virginia Metal Industries, which allowed the affirmative use of the promissory estoppel doctrine in a construction bidding case. This Note also examines the majority of other jurisdictions that have allowed promissory estoppel causes of action in construction bidding cases and discusses their sound and logical reasoning.
Lu Ann Brown, Contracts: Is Promissory Estoppel Forever Estopped in North Carolina - Home Electric Co. of Lenoir, Inc. v. Hall & (and) Underdown Heating & (and) Air Conditioning Co., 10 Campbell L. Rev. 293 (1988).