Now that the Chrsyler asset sale has been consummated, there apparently will be ample numbers of angry yterminated car dealers thinking about legal remedies. Especially for those who recently purchased or invested ample money in a dealership, a very recent Illinois Surpeme Court decision may become popular for some of those seeking remedies as it explictly allows a promissory estoppel remedy even when a contract-based recovery would not succeed. The damages awarded may be limited but could prove better than nothing IF a source of funds could be found. The April 2, 2009 decision is Newton Tractor Sales, Inc. v. Kubota Tractor Corp. , — N.E.2d —-, 233 Ill.2d 46, 2009 WL 886866 (Ill.). The Court’s free version of the opinion is here. There may also be exploration of claims that seek to reach pockets of insurance, such as D & O coverage.