Sprolls v. Chevrolet

Plaintiff Melvin Sprolls, proceeding pro se, sued Webb Chevrolet after the dealership refused to complete the sale of a 2020 Corvette Stingray, asserting six counts including breach of contract, promissory estoppel, consumer fraud, due process violations, tortious interference, and common law fraud. The circuit court granted Webb's combined motion to dismiss under sections 2-619 and 2-615 of the Code of Civil Procedure, dismissing all counts with prejudice, and denied Sprolls' motion to reconsider. Sprolls appealed, and the First District affirmed in full.

The court held the contract and promissory estoppel claims were barred by the UCC Statute of Frauds because no signed writing evidenced an agreement—the online build sheet was expressly a non-binding estimate—and the part-performance exception did not apply since Webb never deposited or accepted Sprolls' certified checks, which were returned to him. The consumer fraud claim failed because Sprolls' own allegations showed Webb refused the sale and refunded his money upon learning of his resale intent, negating any deceptive scheme, and he could not show actual damages once fully refunded. The due process claim failed for lack of state action, as Webb is a private dealership with no governmental nexus, and title never passed absent a valid contract under UCC section 2-401. The tortious interference and fraud claims failed for lack of specificity, absence of an identifiable third-party relationship, and failure to plead reliance or damages. Arguments under the Magnuson-Moss Warranty Act were forfeited as raised for the first time on appeal.

The decision offers practical guidance on pleading standards for consumer and commercial disputes involving failed vehicle sales, particularly the strict application of the Statute of Frauds and the actual-acceptance requirement for the part-performance exception.