OH STATEOhio Court of Appeals
2011

Evans, Mechwart, Hambleton & Tilton, Inc. v. Triad Architects, Ltd.

196 Ohio App. 3d 784Ohio Court of Appeals • Decided 2011Reversed

HOLDING

EMH & T, a civil engineering subcontractor, sued Triad Architects for payment under two contracts containing pay-when-paid clauses. The contracts stated the architect would pay the subcontractor only after the owner paid the architect. When the owner didn't pay, Triad refused to pay EMH & T. Ohio's Court of Appeals ruled that pay-when-paid clauses are timing mechanisms, not excuses to avoid payment entirely. The contractor must pay the subcontractor within a reasonable time regardless of whether the owner has paid.

KEY FINDINGS

Pay-When-Paid

Pay-when-paid clauses don't eliminate your right to payment—they just delay when payment is due. The contractor still owes you money.

Pay-If-Paid

If the contractor hasn't received owner payment, they must still pay you within a reasonable time. You're not stuck waiting indefinitely.

FULL COURT OPINION