NV STATENevada Supreme Court
2012

Certified Fire Protection, Inc. v. Precision Construction, Inc.

128 Nev. 371Nevada Supreme Court • Decided 2012Enforced
FLAGSHIPLien RightsCited 159 times

HOLDING

Certified Fire Protection bid on a fire sprinkler system for a warehouse project but refused to sign the subcontract because the terms differed from their bid. Work was never completed. Certified later sued for payment under quantum meruit (payment for work done even without a contract). The Nevada Supreme Court ruled against Certified, holding that a subcontractor cannot recover payment when no actual work was performed and no contract was signed, especially when design drawings are incomplete or installer-specific.

KEY FINDINGS

Lien Rights

Never start work without a signed contract in place. If you do work without a signed agreement, you may not be able to recover payment even if the general contractor benefits.

FULL COURT OPINION