Termination Claims in Nutshell

Termination occurs when the employer instructs abreaching party under the contract whereas a
contractor to permanently stop the performancenon material breach will entitle the non breaching
of work and leave the site. Construction contractsparty to recover damages but will not releases
specify each party’s rights, obligations, andhim or her from further obligations. However,
remedies for termination. Termination onthere is no litmus test that can readily distinguish
construction projects often results in claims andthe material breach from the non material breach.
disputes; therefore, the decision to proceed withAn immaterial breach of contract is therefore a
this option should not be taken lightly.trivial breach of contract and does not vitiate the
 contract. For example, a contractor for a HVAC
There are two general types of terminationsystem under which the maintenance is
typically addressed in construction contracts:periodically taken place does not make inspections
termination for convenience and termination foron a regular basis. This act is a technical breach of
cause (sometimes referred to as termination forthe contract but is immaterial as long as the
default). In a termination for convenience, theultimate objective of continuity of uninterrupted
owner may terminate the contract for whateveroperation has been ensured.
reason it wishes, such as economic/business 
reasons, or as the most expeditious way ofBreach of contract is an actionable wrong.
eliminating a non-performing contractor withNon-compliance with the terms and conditions
minimum risk of a legal dispute. Contractor’sagreed upon entitles the party violating the same
remedies for termination for convenience varyto resort to remedies available. Remedies for
from contract to contract, but may include abreach of contract may be embodied within the
reasonable cost of work performed prior toletters of the contract itself or in the absence of
termination, including profit, anticipated profits onspecific provisions in cases of breach; the
uncompleted work, justifiable and reasonableapplicable laws will supply the remedies. Common
termination costs including project wind-downremedies for breach of contract more often
costs and other costs as may be mutually agreed.includes demand for specific performance or
 rescission of the contract or claim for damages. It
Termination for cause may occur when thebears stressing that good faith must be exercised
owner believes the contractor has not performedat all times. Full compliance with the terms and
according to its contractual obligations and thusconditions laid down and specified in the contract
has materially breached the agreement. Breach ofmust be observed. Breach of contract will
a contract may terminate the obligations of thedefinitely expose the erring party to liabilities,
contract. Either one party or both parties havepenalties and of course to such tremendous
failed to perform an obligation as envisaged underamount of inconvenience.
the contract. A breach may usually occur when a 
party refuses to perform the contract, doesSome of the more commonly cited reasons for
something that the contract prohibits, or preventsterminating a contract for cause include failure to
the other party from performing its obligations.pay labor, subcontractors, vendors, or material
However, not all breaches end up in contractsuppliers, failure to meet the project schedule or
close-out.diligently perform the work, defective or deficient
 performance, failure to follow applicable laws or
A material breach is controversial that goes toregulations and failure to consistently follow safety
the heart of the contract. The injured party canrequirements.  
seek damages; that is, a monetary compensation 
enough to cover economic losses resulting fromSince some construction contracts provide for
the breach of contract. For example, a contractorexcusable delays, such as force majeure, the
uses materials that are not in compliance with thedecisions to terminate for cause must also
specification. A material breach is any failure toconsider events which are excusable under the
perform that permits the other party to thecontract and prevent the contractor from
contract to either compel performance, or collectperforming as required. Termination-for-cause
damages because of the breach. If the contractorcontract clauses vary from contract to contract,
in the above example had been instructed to usebut some may require the owner to provide
copper pipes, and instead used iron pipes whichproper notice to the contractor of its alleged
would not last as long as the copper pipes wouldbreach or failure to perform and provide a
have, the employer can recover the cost ofreasonable period for the contractor to cure, or
actually correcting the breach - taking out the ironstart to cure, the alleged breach.
pipes and replacing them with copper pipes. A 
contractor’s refusal to start work is clearly aTypical claims from owners under termination for
material breach whereas a contractor’scause include, but are not limited to, the following,
installation of wrong ironmongery would be a nonto the extent that they are not waived by
material breach.contract the extended project duration and
 overhead costs (e.g., replacing one contractor with
Various circumstances can worsen to a degreeanother almost invariably results in overall project
that a disgruntled contractor has no option but todelays), loss of profits or deferred production,
abandon the contract and walk off the site.liquidated damages or actual damages for delay
Whether due to non payment, inadequate designand cost to complete the project if the final
drawings, too many instructions that cause theproject costs exceed the value of the terminated
works technically different than envisaged in thecontract less amounts paid to the terminated
original contract, excessive employer intervention,contractor.
lack of cooperation from the engineer, or 
otherwise, the circumstances can be simplyTypical claims from contractors under termination
beyond the control of the contractor so that thefor cause may include costs to bid the project,
decision to abandon the contract becomesmobilization and demobilization costs, anticipated
inevitable. An analysis of when a contractor mayprofit on the project, costs for work performed
justifiably abandon the contract begins with thebut not paid, home office overhead costs,
fact of materiality. A breach is considered materialwinding-down costs, damages for loss of good will
if it substantially deviates the purpose of theloss of future business due to potential negative
contract and is serious enough to justify thepublicity following termination and betterment
other party in abandoning the contract.issues such as changes or upgrades included in the
 owner’s cost-to-complete damage model that
A material breach releases the non breachingare above and beyond the contractor’s
party from all obligations further owed to theoriginal scope of work.