WY STATEWyoming Supreme Court
1992

JBC of Wyoming Corp. v. City of Cheyenne

843 P.2d 1190Wyoming Supreme Court • Decided 1992Affirmed

HOLDING

JBC, a general contractor on a $20+ million pipeline project in Wyoming, went to arbitration with the City of Cheyenne over unpaid amounts. The arbitrator awarded JBC consequential damages (30% per year on unpaid sums) even though JBC never formally submitted this claim through the contract's required claims procedure. The Wyoming Supreme Court sided with the lower court and struck down the consequential damages award, ruling the arbitrator exceeded his authority by awarding damages that weren't properly submitted through the contractual process.

KEY FINDINGS

Dispute Resolution

Always submit all claims—including consequential damages—through the exact procedure your contract requires, or you may lose the right to recover them even if an arbitrator initially awards them.

Change Order

Arbitrators can only decide issues that are actually submitted to them; failing to formally present a claim type means it's off the table, regardless of the merits.

FULL COURT OPINION