Tim Huey Corp. v. Global Boiler & Mechanical, Inc.

649 N.E.2d 1358 | Appellate Court of Illinois | 1995

enforcedCited 38 timesBATTLE_TESTEDTexas
View on Court Website

What This Case Means for Subcontractors

Tim Huey Corp. hired Global Boiler & Mechanical to build a cogeneration facility for $687,175, but Global stopped work in May 1990 after being paid $412,516, claiming Huey breached the contract. The dispute went to arbitration. The Illinois Appellate Court ruled that arbitration awards are nearly impossible to overturn—courts won't vacate them for errors in judgment, mistakes of law or fact, or disputes over damages unless there's fraud, bad faith, or a clear violation of the contract's core terms. This means subcontractors who agree to arbitration should understand they have very limited appeal options if they lose.

Key Takeaways

  • Arbitration clauses are extremely difficult to challenge in court—don't rely on appealing an arbitration loss unless you can prove fraud or bad faith
  • Written change orders are essential; the contract required them for extra work, so verbal agreements won't protect you if disputes arise
  • Before signing a contract with an arbitration clause, understand the arbitrator's authority and the law that governs the agreement (this contract used Texas law despite being in Illinois)
  • If you stop work, document your reasons thoroughly—the other party will likely claim breach, and arbitration awards are hard to overturn

Courts do not vacate arbitration awards for mere error in judgment or mistakes of law or fact.

Appellate Court of Illinois, 1995

Frequently Asked Question

Can I appeal an arbitration decision if the arbitrator made a mistake?

No, not easily. Courts almost never overturn arbitration awards for errors in judgment, mistakes of law or fact, or disagreements over damages. You can only challenge an award if you can prove fraud, bad faith, or that the arbitrator violated the contract's core terms. This is why it's critical to negotiate arbitration clauses carefully before signing.

Related Cases

Atlantic Marine Constr. Co. v. United States Dist. Court for Western Dist. of Tex.

2013reversed

Forum-selection clauses in federal contracts are enforced through §1404(a) transfer motions, not §1406(a) dismissals, and must be given controlling weight except in exceptional circumstances.

Texas Natural Resource Conservation Commission v. IT-Davy

2002voided

Sovereign immunity bars a contractor's breach-of-contract suit against a state agency absent express legislative consent; neither the agency's conduct, contract terms, nor general statutes waive immunity from suit.

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

2004enforced

A contractor must exhaust administrative remedies established by a regional transportation authority before pursuing breach of contract claims in court, even when the authority lacks governmental immunity from suit.

Edwin P. Harrison, and United States of America, Party in Interest v. Westinghouse Savannah River Company

1999reversed

The Fourth Circuit reversed the district court's dismissal, holding that the False Claims Act broadly reaches false statements made to obtain government contract approval, not just false payment claims themselves.

General Services Commission v. Little-Tex Insulation Co.

2001voided

The State does not waive sovereign immunity from breach-of-contract suits by accepting contract benefits; Chapter 2260's administrative procedure is the exclusive remedy for such claims.

Green International, Inc. v. Solis

1997modified

No-damages-for-delay clauses in construction contracts need not meet the conspicuousness requirement established in Dresser for exculpatory negligence clauses, and such clauses are enforceable to bar delay damages absent specific exceptions.