Does a Contractor Need to Give a Written Estimate of the Total Costs for a Home Improvement Project ?

In L.L.C, v. Slepian, 358 Ill. App. 3d 545, 550, 831 N.E.2d 1169, 1173, 294 Ill. Dec. 844 (2005), the contractor argued that it was impossible to provide a written estimate of the total costs because the homeowners were "constantly changing the scope and therefore the cost of the project." Slepian, 358 Ill. App. 3d at 549, 831 N.E.2d at 1172. The Court held that plaintiff was not excused from the written contract requirement, stating: "There is no exception under the Act for projects that become unpredictable in scope and nature. To the contrary, the Act appears designed to help define some reasonable boundaries for a home improvement project. The Act requires an estimate of 'reasonable particularity.' Nothing in the Act precludes a contractor from providing an updated estimate or work order as the circumstances may warrant. In any case, this court cannot add exceptions, limitations, or conditions to the statute that the legislature did not express." Slepian, 358 Ill. App. 3d at 549, 831 N.E.2d at 1172-73.