Abrams v. Illinois College of Podiatric Medicine

Brief Fact Summary.

Abrams sued Illinois College of Podiatric Medicine for breach of contract when he was expelled and his professors failed to update him regarding his progression throughout the semester.

Synopsis of Rule of Law.

A binding contract is not created with vague statements expressing that an action will or should be taken.

Facts.

Abrams, a student at Illinois College of Podiatric Medicine (College), failed Physiology 101 twice. College removed Physiology 203 from the next semester and claimed that Abrams would be permitted to retake Physiology 101 in the summer if he passed all his classes. The student handbook claimed that professors would update students about their progress, let students know how they are doing after midterms, and provide suggestions for improvement. Abrams professors failed to update him and he failed two of his courses in the second semester. Abrams was subsequently expelled and sued for breach of contract. The trial court granted judgment to the college.

Issue.

Whether a binding contract is created with vague statements expressing that an action will or should be taken?

Held.

No. The judgment of the trial court is affirmed. The statements in the student handbook do not constitute an offer inviting an acceptance.

Discussion.

A binding contract is not created with vague statements expressing that an action will or should be taken.