TX STATECourt of Appeals of Texas
2009

AMX Enterprises, L.L.P. v. Master Realty Corp.

283 S.W.3d 506Court of Appeals of Texas • Decided 2009Modified

HOLDING

AMX Enterprises sued Master Realty Corp. for unpaid contract work on a hotel flood remediation project, claiming violations of Texas's Prompt Payment to Contractors Act. The court ruled that trial courts cannot delay statutory interest payments due to litigation delays, contractors cannot collect both statutory 18% interest and common law interest simultaneously, and attorney fees for in-house counsel must be calculated at market rates. This decision protects contractors' right to timely interest payments under state law.

KEY FINDINGS

Pay-When-Paid

You are entitled to the full 18% statutory interest under the Prompt Payment Act—courts cannot reduce or delay it because of litigation. Document all unpaid invoices immediately to start the interest clock.

Lien Rights

Do not accept settlement offers that include both statutory interest and common law prejudgment interest. You can only recover one type, so negotiate carefully.

Attorney Fees

If you use in-house counsel for disputes, demand they calculate fees at market rates for similar outside counsel, not at cost-plus rates. This typically results in higher recoverable fees.

FULL COURT OPINION