TX STATETexas Court of Appeals, 4th District (San Antonio)
1996

Chilton Insurance Co. v. Pate & Pate Enterprises, Inc.

930 S.W.2d 877Texas Court of Appeals, 4th District (San Antonio) • Decided 1996Modified

HOLDING

A general contractor (Pate & Pate) hired subcontractor Caliber on a public works project in San Antonio. When Caliber breached the contract, Pate admitted in court that it owed Caliber a specific credit amount for work completed, but then claimed the breach excused it from paying. The Texas Court of Appeals ruled that by continuing to treat the contract as valid after the breach, Pate waived its right to use the breach as an excuse to avoid payment. Caliber won the right to collect the judicially admitted credit amount.

KEY FINDINGS

Pay-When-Paid

If a general contractor admits in court that it owes you money for work performed, it cannot later use your breach as an excuse to withhold that payment if it kept the contract active

Lien Rights

Document all admissions of payment obligations in writing and get them on the record early—they become powerful legal evidence

Broad Indemnification

Continuing to work or treat a contract as ongoing after a dispute weakens the other party's ability to claim breach excuses non-payment

FULL COURT OPINION