Garland Independent School District v. Reeder General Contractors, Inc.

CourtCourt of Appeals of Texas
DecidedMarch 21, 2024
Docket05-22-00855-CV
StatusPublished

This text of Garland Independent School District v. Reeder General Contractors, Inc. (Garland Independent School District v. Reeder General Contractors, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Garland Independent School District v. Reeder General Contractors, Inc., (Tex. Ct. App. 2024).

Opinion

Affirm and Opinion Filed March 21, 2024

In The Court of Appeals Fifth District of Texas at Dallas No. 05-22-00855-CV

GARLAND INDEPENDENT SCHOOL DISTRICT, Appellant V. REEDER GENERAL CONTRACTORS, INC., Appellee

On Appeal from the 162nd Judicial District Court Dallas County, Texas Trial Court Cause No. DC-21-15806

MEMORANDUM OPINION ON REHEARING Before Justices Molberg, Pedersen, III, and Miskel Opinion by Justice Molberg We deny appellant Garland Independent School District’s motion for

rehearing and, on our own motion, withdraw our January 26, 2024 memorandum

opinion and vacate the judgment of that date. This is now the opinion of the Court.

In three issues, Garland Independent School District (the District) appeals the

trial court’s order denying its plea to the jurisdiction. The District argues the Texas

Local Government Contract Claims Act1 does not waive immunity for appellee

Reeder General Contractors, Inc.’s claims for various reasons; the Legislature has

1 TEX. LOC. GOV’T CODE §§ 271.151–.160. not waived governmental immunity for equitable damages claims; and Texas

Government Code § 2251 does not waive a school district’s governmental immunity

for attorney’s fees claims. We affirm in this memorandum opinion.

Background

On October 26, 2021, Reeder sued the District for breach of contract, alleging

the two parties executed a contract for Reeder to perform construction work at

several district campuses, including Jackson Middle School and Lyles Middle

School. The parties executed the contract and related plan documents on February

7, 2018. On May 18, 2018, Reeder had to stop work on the Jackson project when it

“discovered a previously undisclosed electrical feeder line running within the

project’s building foundation footprint[,]” making it “impossible for the piers to be

constructed as called for in the plans.” Reeder alleged the District and the District’s

architect did not complete their redesign for the project until October 16, 2018.

Reeder alleged it incurred significant additional costs resulting from the six-month

delay. It alleged, in accordance with contractual requirements, it submitted a change

order (Proposed Change Order 38) on January 3, 2019, requesting $265,700 for

“additional jobsite costs and general conditions it incurred due to the delay.” Reeder

substantially completed some of the work on December 5, 2019, and submitted a

revised change order, and the parties, eighteen months later, eventually reached an

agreement with the District’s project manager for a $154,504 payment for the work.

Reeder alleged the District presented the change order to the District’s Board of

–2– Trustees for approval in March 2021. The Board “agreed that Reeder was not at

fault and was entitled to the change order,” but Reeder alleged the District has

nevertheless failed and refused to execute the change order. Reeder further alleged

the District prevented Reeder from submitting a final payment request for retainage

withheld on the project, despite the contract’s requirement that retainage be paid

within thirty days after completion of work. Reeder alleged $1,138,995.88 was due

and payable for these breaches. Reeder also alleged a Prompt Payment Act violation

and sought attorney’s fees under “the terms of the contract and Texas law,” including

Chapter 2251 of the Texas Government Code.

On June 3, 2022, the District filed a plea to the jurisdiction. The District

argued the trial court lacked subject matter jurisdiction because governmental

immunity precluded Reeder’s claims. Despite Texas Local Government Code

§ 271.152 (local government entity waives sovereign immunity to suit for breach of

a contract entered into subject to Chapter 271, Subchapter I, of local government

code), the District argued Reeder’s claims did not fall within the Act’s waiver

because Reeder (1) could not establish the element of breach, (2) sought damages

not allowed by § 271.153, and (3) failed to comply with the contract’s “claims”

process for resolving disputes. The District also argued the suit was

“extracontractual in nature and thus sounds in equity despite its mischaracterization

as a breach of contract case,” and that Reeder’s Prompt Payment Act claim did not

fall within any waiver of governmental immunity.

–3– The District also filed a brief in support of its plea to the jurisdiction with

which it included an affidavit from Javier Fernandez, the District’s Director of

Facilities, Planning, and Construction Services. Fernandez stated Reeder failed to

comply with the contract in several ways, including failing to file a “claim” with the

District, to comply with the claims process, to file a written appeal of a decision of

the architect, to file a written appeal of the program manager’s decision, and to

provide written notice of any interference by the District, architect, or program

manager. Fernandez also stated the District had paid all compensation due under the

contract.

On August 5, 2022, Reeder filed its first amended petition. Reeder alleged

the construction contract involved work at five different campuses, but the work at

issue in its suit related to Jackson Middle School and Lyles Middle School, where it

was to build new band halls and renovate other facilities. Prior to submitting its bid,

Reeder was provided a project manual, a set of general conditions for construction,

and plans, which were all incorporated as part of the contract documents governing

the parties’ relationship. According to the contract, the intent of these documents

was to “include all items necessary for the proper execution and completion of the

work by [Reeder].” Reeder alleged it was obligated under the contract to study and

compare the plans to actual observable site conditions prior to beginning its work

“for the purpose of facilitating coordination and construction by [Reeder] and not

the purpose of discovering errors, omissions, or inconsistencies.” Reeder alleged

–4– the contract stated Reeder had no responsibility for “damages resulting from errors,

inconsistencies, or omissions in the contract documents or for differences between

field measurements or conditions and the contract documents” unless Reeder should

have recognized such inconsistencies in its comparison of plans and observable site

conditions and then failed to report to the District’s architect. The contract further

stated Reeder was not “responsible for the adequacy of the . . . design required by”

the plans.

Reeder alleged the District’s plans, prepared by the District’s architect, VLK

Architects, Inc., were “riddled with inconsistencies, omissions, and errors that were

not discoverable by [Reeder] in the exercise of its pre-work ‘study and compare’

obligations.” These defects, in addition to rainfall and other weather conditions,

significantly slowed Reeder’s progress on the Lyles and Jackson projects.

Reeder discovered defects in the plans that prevented it from going forward

on both projects. Reeder alleged it stopped work and submitted requests for

information and then waited for the District, VLK, and the project manager, Jacobs,

to inform it how to proceed with a redesign or workaround. Under the contract,

responses to such requests were to be made “reasonably promptly,” but Reeder

alleged the District, VLK, and Jacobs took 60 days on the Lyles project and 151 days

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Garland Independent School District v. Reeder General Contractors, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/garland-independent-school-district-v-reeder-general-contractors-inc-texapp-2024.