WI STATEWisconsin Supreme Court
2006

1325 North Van Buren, LLC v. T-3 Group, Ltd.

2006 WI 94Wisconsin Supreme Court • Decided 2006Modified

HOLDING

A building owner hired a construction manager to renovate a warehouse into condos. After problems arose, the owner sued for negligence. Wisconsin's Supreme Court ruled that the economic loss doctrine bars negligence claims in construction contracts focused on delivering a finished building product. This means subcontractors and contractors can only sue for breach of contract, not negligence, even if work is done poorly.

KEY FINDINGS

Broad Indemnification

You cannot sue for negligence in construction contracts—only for breach of contract. This limits your damages and remedies significantly.

Liquidated Damages

The economic loss doctrine applies when the main purpose of the contract is delivering a completed building or product, not just providing services.

Insurance Requirements

Insurance coverage disputes matter: professional liability and general liability policies may not cover contract breach claims, leaving you without protection.

FULL COURT OPINION