Patrick Engineering, Inc. v. the City of Naperville

Summary

The court held that equitable estoppel cannot be asserted against a municipality based merely on employees' apparent authority or job titles. A plaintiff must plead specific facts showing an affirmative act by the municipality or an official with express authority, together with reasonable and detrimental reliance; Patrick Engineering did not do so. The court also held that the invoices did not establish an account stated because they were inconsistent, failed to identify a final balance, and did not show the City's agreement to pay. No separate opinions were filed.