In City Stores v. Ammerman 266 F.Supp. 766 (D.D.C. 1967)the
Court granted specific performance.This case arose during the construction of Tyson's Corner
Mall.City Stores had a contract
for an anchor store in Tyson's.In
this case, the Court found that the prestige of being in a new mall was a
unique opportunity (there weren't many malls back then).In addition, the Court felt that there
was a very specific plan and supervision would not be required.It's the same basic rule of law as in Northern
Delaware Indus. Development Corp. v. E.W. Bliss Co., but the Court was more aggressive in their opinion.This is an example of how modern courts
are beginning to order specific performance more often.