TX STATETexas Court of Appeals, 4th District (San Antonio)
2004

Alamo Community College District v. Browning Construction Co.

131 S.W.3d 146Texas Court of Appeals, 4th District (San Antonio) • Decided 2004Enforced

HOLDING

Browning Construction sued Alamo Community College District for breach of contract after project delays. The jury awarded Browning over $3 million in damages despite a no-damages-for-delay clause in the contract. The court ruled that the college district is not immune from suit under Texas law, and that a contractor can recover delay damages when the owner actively interferes with the work, even if the contract says otherwise.

KEY FINDINGS

Pay-When-Paid

No-damages-for-delay clauses are not absolute—if the owner actively interferes with your work, you may still recover delay costs in Texas

Lien Rights

Government entities like community colleges cannot hide behind sovereign immunity to avoid paying contractors for breach of contract

Change Order

Document all owner-caused delays and interference in writing; this evidence is critical to overcoming a no-damages-for-delay clause

FULL COURT OPINION