TN STATETennessee Supreme Court
1996

Koch v. Construction Technology, Inc.

924 S.W.2d 68Tennessee Supreme Court • Decided 1996Modified
Pay-When-PaidCited 19 times

HOLDING

A painting subcontractor sued a general contractor over unpaid work on a Memphis housing project. The general contractor had a 'pay when paid' clause stating the subcontractor would only be paid when the general contractor received payment from the owner. The Tennessee Supreme Court ruled that 'pay when paid' clauses are timing provisions, not conditions that eliminate the general contractor's obligation to pay. The court found the clause did not shift the owner's credit risk to the subcontractor without very clear language stating that intent. This decision protects subcontractors from being left unpaid if the owner fails to pay the general contractor.

KEY FINDINGS

Pay-When-Paid

A 'pay when paid' clause delays payment timing but does not eliminate the general contractor's obligation to pay you—the general contractor still owes you even if the owner doesn't pay them

FULL COURT OPINION