Estoppel Bars Specific Performance After Termination Notice, Even With Substantial Compliance

In City Choice Group v. TMC Grand Blvd Land Co., Judge Adrogué granted partial summary judgment holding that City Choice, having delivered an unequivocal termination notice during the inspection period of a $22.5 million land purchase agreement, was estopped from seeking specific performance of the contract it purported to terminate—even though it substantially complied with notice provisions and the termination was not subject to strict compliance standards applicable to option exercises. The court separately denied TMC's motion for pre-judgment release of $100,000 in independent consideration held in escrow, ruling that TMC must comply with statutory requirements for a writ of attachment rather than seeking immediate release.