A business case document is an important project management decision-making tool for planning and evaluating potential investments in technology and process improvement projects. However, the effectiveness of traditional business case approaches for evaluating complex information technology (IT) investments, such as enterprise systems implementations is often questioned. A business case is a document created by an organization that outlines the expected benefits, costs, risks, and feasibility of a possible investment. Creating an effective business case for complex IT investments is difficult due to the uncertainty around the expected benefits, costs, risks, and timing for these complicated organizational projects that typically involve significant technological and organizational change throughout the lifecycle of the IT system. This paper reports on our analysis of the current challenges and outlines a framework for guiding further study.