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Non-compliance with Change Order Requirements Dooms Differing Site Conditions Claim

On November 6, 2020, the Kentucky Court of Appeals affirmed a trial court’s decision dismissing a contractor’s differing site conditions claim on a sewer replacement project. In TSI Construction, Inc. v. Louisville and...more

Kentucky Fried Claim: Contractor Preserves Immunity from Suit by Complying with Government Contract Specifications

Recently, in Cross v. L-M Asphalt Partners, Ltd., the Kentucky Court of Appeals upheld a contractor’s immunity from suit for negligence, where the contractor complied with the contract and construction specifications provided...more

Federal Prompt Pay Act Does Not Afford Subcontractors Right to Sue General Contractor

On October 15, 2020, in EMTA Insaat Taahhut ve Ticaret A.S. v. Cosmopolitan Incorporated, a federal district court held that the federal Prompt Pay Act (PPA) (31 U.S.C. §§ 3901, et al.) does not create a private right of...more

Suing a Design Professional in Texas? Make Sure to Include a Certificate of Merit in Your Pleading

On August 4, 2020, the Court of Appeals of Texas (First District) reversed a trial court’s denial of an engineering firm’s motion to dismiss finding that the plaintiff’s failure to attach the required certificate of merit...more

Minnesota Automatic-Approval Rule Secures CUP and Saves Solar Project

One of the challenges of renewable energy development is managing the permitting process. Understanding how to navigate state and local laws can be integral to a developer’s permitting success, especially where a community...more

Contract, Project, and Arbitration in Florida? State Has Personal Jurisdiction Over Action to Enforce Arbitration Award

On June 24, 2020, in Sayers Constr., LLC v. Timberline Constr., Inc., et al., a Florida District Court of Appeal affirmed a trial court’s denial of a contractor’s motion to dismiss. The contractor moved to dismiss for lack of...more

Fraudulently Filing Lien Backfires on Contractor

Liens represent one of the primary mechanisms by which contractors, subcontractors, and other downstream parties secure payment rights under a construction contract. When utilized properly, filing a lien may induce an owner...more

Timing Is Everything: Miller Act Notice Defect Saves Surety

The Miller Act protects subcontractors from nonpayment on federal projects by requiring prime contractors to issue payment bonds. To obtain relief under the Miller Act, a subcontractor must (1) give the prime contractor...more

New York is Pro-Choice on Forum Selection Clauses

In Somerset Fine Home Building, Inc. v. Simplex Industries, Inc., the Appellate Division of the Second Department in New York upheld a dismissal based on the plaintiff’s breach of the parties’ forum selection clause. Somerset...more

Don’t Be Unreasonable: Equitable Adjustment Conditioned on Government Contractor’s Proof of Reasonable Interpretation of Contract

The U.S. Court of Appeals for the Federal Circuit, in U.S. Army Corps of Engineers v. John C. Grimberg Co., Inc., recently reversed an Armed Services Board of Contract Appeals (ASBCA) decision that a federal contractor was...more

Watch Your Stipulation! Award Confirmed Despite Arbitrator Exceeding Contractual Scope of Authority

Once parties agree to arbitrate, courts generally defer to the arbitrator’s judgment regarding resolution of a dispute. The prevailing approach in many states is to not set aside an arbitration award unless the arbitrator...more

Prior Material Breach May Excuse Performance, but the Factfinder Must Agree It Was a Material Breach

In most jurisdictions, a party may be excused from any future performance under a contract by the prior material breach of the other party. A “prior material breach” is typically defined as conduct that deprives the injured...more

Notice Your Lien or Kiss it Goodbye

Like many states, Minnesota requires subcontractors and suppliers to send pre-lien notices to owners to perfect mechanic’s lien rights. Failure to comply with the pre-lien notice statute can prove fatal to a lien enforcement...more

Does Your Construction Contract Involve Interstate Commerce? If So, Expect Your Arbitration Agreement to Be Enforced

Whether an arbitration agreement is enforceable is a frequently litigated matter in construction disputes. Federal policy strongly favors arbitration. Typically, the Federal Arbitration Act (FAA) will preempt any contrary...more

Extra Work Claim Waived for Not Following Change Request Procedures

On May 29, 2020, in Constr. Drilling, Inc. v. Engineers Constr., Inc., the Vermont Supreme Court upheld a trial court’s judgment in favor of general contractor on an extra work payment dispute. The Supreme Court agreed with...more

Don’t Forget to Certify Within Six Years: Recent Opinion Addresses Timeliness of Government Contractor’s Appeal

On May 19, 2020, the Federal Circuit upheld summary judgment against a government contractor for failure to file a claim timely within the six-year time limit prescribed by the Contract Disputes Act (CDA). In Electric Boat...more

No Mechanic’s Lien Rights for Providers of Geotechnical and Construction Observation Services in Delaware

On May 15, 2020, in Geo-technology Associates Inc. v. Capital Station Dover, LLC, the Delaware Supreme Court dismissed an action to enforce a mechanic’s lien because the geotechnical and construction observation services...more

Promises to Pay Sub-subcontractor may Expose General Contractor to Liability for Unjust Enrichment

On May 14, 2020, in James G. Davis Constr. Corp. v. FTJ, Inc., the Virginia Supreme Court upheld a judgment on an unjust enrichment claim in favor of FTJ, a drywall supplier on a condominium project, against Davis, the...more

An Insurer’s Duty to Defend does not Extend to a Construction Claim that Falls Clearly Within a Policy Exclusion

Like most states, Florida follows the rule that an insurer’s duty to defend is separate from and broader than its duty to indemnify for a potentially covered occurrence. Last week, in South Winds Construction Corp. v....more

In Georgia, Rely on an Affiliate’s or Individual’s General Contractor’s License at Your Own Peril

On May 5, 2020, the Georgia Court of Appeals affirmed a trial court summary judgment ruling dismissing a residential contractor’s claims against an owner because the contractor was not properly licensed. In LFR Investments,...more

Recent Court Order Excluding Expert Testimony Offers Useful Reminders and Lessons for Construction Litigants

Construction claims often feature supporting testimony from design and/or scheduling experts, and exclusion of that testimony either by disqualification of the expert or a finding that the testimony is otherwise inadmissible...more

We Just Learned We Have a COVID-Positive Employee: Do We Have to Tell OSHA?

Employers long have been required to record and report work-related injuries and illnesses to OSHA. A new question in the pandemic environment is whether you have to record an employee who tests positive for COVID-19...more

OSHA Issues Temporary Guidance on Enforcement of Employers’ COVID-19 Recordkeeping

On April 10, 2020, the Occupational Safety & Health Administration (OSHA) issued interim guidance for the enforcement of employer reporting requirements arising from COVID-19 illnesses that will remain in effect during the...more

Federal Court Rules Contractor Is Not Intended Third-Party Beneficiary under Owner-Engineer Agreement

In March, a Massachusetts federal court addressed whether a design-builder contractor could recover for breach of contract under an intended third-party beneficiary theory against a design firm hired by the project owner to...more

Sox Are ‘Slippery When Wet’: Contractor May be Liable for Injury Caused by Work Installed According to Customer Specifications

An Illinois appellate court recently addressed the scope of negligence liability for a slip and fall injury on a newly installed roof at the Chicago White Sox Stadium. In 2013, a maintenance employee slipped on the roof at...more

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