Can the Language of City Ordinance Evince An Intent to Create a Contract ?

In Unterschuetz v. City of Chicago, 346 Ill. App. 3d 65, 71, 803 N.E.2d 988, 281 Ill. Dec. 367 (2004), the court determined that the language of the city's ordinance that established its personnel administration did not evince an intent by the city council to create a contract between the city and its employees. Unterschuetz, 346 Ill. App. 3d at 72-73. Rather, the ordinance stated the policy that the city intended to carry out until such time as the city council wished to change those policies. This court noted that "contract" was not used in the ordinance and the sections cited by the plaintiff contained "none of the essential requirements for creating a contract." Unterschuetz, 346 Ill. App. 3d at 73.