A contractor performed hurricane repair work on Virgin Islands schools under emergency contracts worth about $3.9 million. Government officials verbally requested additional repairs worth $6.7 million, but never issued written change orders. The contractor sued for the extra work. The court ruled that a jury should decide whether the verbal requests created a binding contract modification, reversing the government's summary judgment win.
Verbal change orders can be enforceable even without written documentation if government officials clearly requested the work and you performed it in reliance on those requests.