FEDERALCourt of Appeals for the Tenth Circuit
1990

Transpower Constructors, a Division of Harrison International Corporation, Plaintiff-Appellee/cross v. Grand River Dam Authority, an Oklahoma Public Corporation, Defendant-Appellant/cross-Appellee, and Benham Group, Inc., a Delaware Corporation, Transpower Constructors, a Division of Harrison International Corporation v. Grand River Dam Authority, an Oklahoma Public Corporation, and Benham Group, Inc., a Delaware Corporation

905 F.2d 1413Court of Appeals for the Tenth Circuit • Decided 1990Enforced

HOLDING

Transpower Constructors sued the Grand River Dam Authority for breach of contract and the construction manager Benham Group for negligence over a dam project. The court ruled that contractors can recover damages using reasonable estimates of losses—they don't need exact mathematical proof. The court also said indemnification clauses must be crystal clear to protect a construction manager from liability for its own negligence; vague language won't cut it.

KEY FINDINGS

Change Order

You can win a damages claim with reasonable approximation of losses. You don't need perfect accounting or mathematical precision to prove what you lost.

Broad Indemnification

Indemnification clauses only protect the other party if the language is unambiguous and explicit. Unclear or broad indemnity language won't shield them from their own negligence.

Dispute Resolution

Construction managers can be held liable in negligence even when a contract exists. Don't assume a contract clause automatically protects the project manager from all claims.

FULL COURT OPINION