AK STATEAlaska Supreme Court
1992

Conam Alaska v. Bell Lavalin, Inc.

842 P.2d 148Alaska Supreme Court • Decided 1992Enforced

HOLDING

Conam Alaska, a subcontractor on a North Slope project, sued Bell Lavalin for breach of contract and professional negligence. The court ruled that Conam's failure to perform was excused because Bell Lavalin breached its duty to grant a time extension. While the jury awarded contract damages to Conam, the court rejected the professional negligence claim due to insufficient proof of causation. The key lesson: a prime contractor cannot terminate a subcontractor for nonperformance if the prime itself caused the delay through breach.

KEY FINDINGS

Change Order

Document all requests for time extensions in writing. If the prime denies or ignores your extension request, you have a defense against termination for delay.

Flow-Down

Contract damages are easier to prove than professional negligence damages. Focus on quantifying direct losses (labor, equipment, overhead) rather than pursuing negligence claims.

Termination for Convenience

A 'total breach' is required to justify termination. Partial breaches or isolated failures do not give the prime the right to terminate your subcontract.

FULL COURT OPINION