TX STATETexas Court of Appeals, 3rd District (Austin)
2010

Eco Built, Inc. and Ed Travis v. Mark Lulfs D/B/A Paperhanger Plus Landmark Organization, L.P. And California Wholesale Material Supply, Inc. D/B/A Calply

Texas Court of Appeals, 3rd District (Austin) • Decided 2010Modified

HOLDING

Eco Built, a subcontractor, breached a construction contract on the Hilton Austin project and argued it was discharged from payment obligations because Landmark (the general contractor) also breached first. The Texas Court of Appeals rejected this argument, ruling that even when one party materially breaches, the other party cannot simply stop paying for work already performed under the contract. The court held that both parties can have valid damage claims—the breaching party doesn't get a free pass on payment just because the other side also breached.

KEY FINDINGS

Pay-When-Paid

If you breach a contract, you still owe payment for work the other party completed before the breach occurred—you can't use their breach as an excuse to withhold payment for prior performance.

Termination for Convenience

Continuing to work or treat a contract as active after the other party breaches means you've likely waived your right to terminate and walk away without further obligations.

Retention

Document all work completed and invoices carefully, because courts will enforce payment obligations for completed work even in disputes where both sides have breached.

FULL COURT OPINION