FEDERALCourt of Appeals for the Fifth Circuit
2004

Martin K. Eby Construction Company, Inc. v. Dallas Area Rapid Transit

369 F.3d 464Court of Appeals for the Fifth Circuit • Decided 2004Enforced
FLAGSHIPDispute ResolutionChange OrderCited 1,071 times

HOLDING

Martin K. Eby Construction sued DART (Dallas Area Rapid Transit) over construction delays caused by design defects. The court ruled that Eby had to use DART's internal dispute process before filing a lawsuit, even though DART isn't a government agency protected by immunity. This means contractors must follow the administrative steps outlined in their contract and the client's procurement rules before going to court.

KEY FINDINGS

Dispute Resolution

Always check your contract for dispute resolution procedures and administrative remedy requirements—you must follow them before suing, regardless of who the client is.

Change Order

Design defects and delays don't automatically let you skip the administrative process. You need to exhaust internal remedies first, even if you have a strong claim.

FULL COURT OPINION