The Howard P. Foley Company v. J. L. Williams & Co., Inc., Highlands Insurance Co., and Standard Brands, Inc.

622 F.2d 402, 1980 U.S. App. LEXIS 16930
CourtCourt of Appeals for the Eighth Circuit
DecidedJune 5, 1980
Docket79-1867
StatusPublished
Cited by3 cases

This text of 622 F.2d 402 (The Howard P. Foley Company v. J. L. Williams & Co., Inc., Highlands Insurance Co., and Standard Brands, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Howard P. Foley Company v. J. L. Williams & Co., Inc., Highlands Insurance Co., and Standard Brands, Inc., 622 F.2d 402, 1980 U.S. App. LEXIS 16930 (8th Cir. 1980).

Opinion

ROSS, Circuit Judge.

This action arose out of the construction of a nut processing plant and warehouse in Fort Smith, Arkansas. A contract was entered into between appellee Standard Brands, Inc. (Standard Brands), the project owner, and appellee J. L. Williams & Co., Inc. (Williams), the prime contractor. A number of subcontractors were retained to work on the project, including appellant, The Howard P. Foley Company (Foley), who was hired to do the electrical work. Appellee Highlands Insurance Co., was the surety for Williams.

Foley and Williams entered into a contract whereby Foley agreed to perform all the work and furnish all materials outlined in the owner’s specifications dealing with electrical work. The subcontract was a standard form, but typewritten onto the form was the following paragraph:

Time is of the essence in this contract. J. L. Williams & Co., Inc. has agreed to a liquidated damage clause in our contract with the owner. It is therefore imperative that the Bar Chart Schedule attached to this contract be strictly adhered to and any delays or deviations from this schedule be brought to the immediate attention of J. L. Williams & Co., Inc.

The paragraph was followed by a handwritten note, “No chart included,” which was initialed by a representative of appellants.

The subcontract also provided as follows:

1. (a) The parties agree that in the event the Owner makes changes in the work to be performed by Contractor which increases or decreases the work or cost of work of the Subcontractor the Subcontract price will be changed accordingly, providing that such increases or decreases are approved in writing prior to such changes.
(b) * * * The Subcontractor shall prosecute the work undertaken in a prompt and diligent manner whenever such work, or any part of it, becomes available, or at such other time or times as the Contractor may direct, and so as to promote the general progress of the entire construction, and shall not, by delay or otherwise, interfere with or hinder the work of the Contractor or any other subcontractor. * * The Subcontractor agrees to pay Contractor for any and all damages which are caused by Subcontractor’s failure to furnish the materials and/or perform the work required by this Subcontract in the time and manner provided herein.

There was no corresponding clause in this instrument whereby the contractor assumed liability to the subcontractor for delay occasioned by the acts of the contractor.

Foley contended that the subcontract incorporated all the provisions of the main contract between Standard Brands and Williams (hereinafter the specifications), and the trial court analyzed the issues in terms of this incorporation. 1 Foley sought dam *404 ages for delay in finishing the project on the theories that delay damages are recoverable under the terms of the contract and that appellees Williams and Standard Brands wrongfully interfered with appellant’s performance of the contract.

The trial court issued a memorandum opinion and judgment in which it declared that under either theory the contract did not provide Foley with delay damages. We affirm in part and reverse in part.

I. Contractual Damages.

Of pivotal importance in the trial court’s decision was Section IB of the specifications:

07. TIME OF COMPLETION:
(A) It is the desire of the Owner to have the work completed by May 1, 1975.
(B) The Contractor shall stipulate on the Bid Proposal Form the number of calendar days required to complete the work. Based on the Contractor’s stipulated time, the sum of $3,000.00 per day will be assessed against the Contractor for failure to complete the work within the stipulated time for causes beyond his control as set forth in the General Conditions.
(C) 1. It is essential that the two-story portion of the facility be watertight and in a condition to receive processing and packaging equipment for installation by December 15, 1974.
2. The Owner agrees to pay the Contractor the sum of $1500.00 per day as a bonus if the two-story portion of the facility is completed as stated above and if all work is completed prior to May 1, 1975 and the facility is completely operational.
3. Any authorized extension of time beyond May 1,1975 for any reason, will preclude the payment of the bonus. (D) The time set for completion for work to be done under this contract is an ESSENTIAL condition of the contract.

The trial court decided that the contract allowed the owner a right to claim damages for delays but omitted a corresponding provision for the benefit of the contractor. Instead, the contractor was provided a bonus if he gave timely performance. Although Article 42(d) 2 of the specifications bound the contractor to the subcontractors by all the obligations that owner assumed to contractor, a substitution of parties in the time of completion paragraph does not result in a payment of delay damages by contractor to subcontractor. Owner in the specifications did not expressly agree to pay delay damages and substituting the parties by incorporation (contractor for owner and subcontractor for contractor) does not result in the contractor derivatively assuming delay obligations towards subcontractor.

Foley on appeal quotes Section 1C, Article 26(e) of the specifications which provide for an extension of time: “This Article does not exclude the recovery of damages for delay by either party under other provisions in the Contract Documents.” 3 He *405 contends that these damages are due under Section 1C, Articles 24, 25 and 29 of the specifications. These Articles provide for changes and extra work, 4 claims for extra cost and damages, 5 and suspension of work. 6 In addition to mentioning that these sec *406 tions have writing or notice requirements, compliance with which was not decided by the trial court, appellees claim that the law in Arkansas is to the effect that “the parties contract with a view to the possibility of delay and if damages for delay are to be recovered the contract must contain an express provision to that effect,” citing Blair v. United States, 147 F.2d 840, 849 (8th Cir. 1945). This was stated by the Supreme Court of Arkansas in Brown & Froley v. Monroe County Road Imp. Dist., 153 Ark. 606, 612, 241 S.W. 39, 41 (1922):

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622 F.2d 402, 1980 U.S. App. LEXIS 16930, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-howard-p-foley-company-v-j-l-williams-co-inc-highlands-ca8-1980.