N&N Contractors installed 68 extra precast concrete panels beyond their original contract with Urban Masonry. Urban's project manager acknowledged the extra work and promised additional payment, but later refused to pay. The court ruled that N&N was entitled to full compensation for the extra panels, plus attorneys' fees and interest. The case was remanded only to recalculate the attorneys' fees amount. This decision protects subcontractors who perform extra work with the general contractor's knowledge and verbal approval.
Document all extra work in writing immediately—get the GC's acknowledgment in email or change order form, not just verbal promises
You can recover payment for work beyond the original contract scope if the GC authorized it, even without a formal change order
Keep detailed records of what was actually installed versus what the contract required—this evidence won the case for N&N