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Semac Electric Co. v. Skanska USA Building, Inc.

Conn. App. Ct.February 11, 2020No. AC41054Cited 6 times
Mixed ResultSkanska USA Building, Inc.$3,857,130.77 awarded
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Case Details

Judge(s)
Alvord; Devlin; Norcott
Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
bench trial

Related Laws

No specific laws identified for this ruling.

Claim Types

Breach of Contract

Outcome

Both parties breached the contract. Trial court found Semac breached by abandoning the project, but Skanska also breached by failing to provide a 48-hour cure period before termination. Skanska awarded $3,857,130.77 in damages for overpayment, but Semac entitled to termination payment calculated by percentage of project completion.

Excerpt

The plaintiff subcontractor, E Co., sought to recover damages from the defendant, S Co., for, inter alia, breach of contract in connection with a dispute arising from a project relating to the expansion and renovation of a hospital. Pursuant to its contract with S Co., E Co. agreed to perform all electrical work for the project. The contract provided that E Co. had a duty to coordinate with S Co., that E Co. had made allowances for all hindrances and delays to its work, and that E Co. would work within S Co.'s schedule, which S Co. may revise from time to time. S Co. had the right to direct a change in E Co.'s work on written notice and, during the course of the project, thirty-eight change orders were issued. After several months, E Co. sent S Co. a notice, alleging a cardinal change to the contract due to issues that arose during the preceding months and asserting that it could only continue to perform under the contract if S Co. agreed to additional financial terms. S Co. responded that E Co.'s refusal to proceed under the contract constituted default and, the next day, S Co. terminated E Co. E Co. alleged that S Co. had breached the contract by its wrongful termination of E Co., and S Co. filed a counterclaim, alleging, inter alia, breach of contract. S Co. also filed a third-party complaint against K and T, the chief financial officer and president of E Co., respectively, alleging, inter alia, fraudulent conduct. The case was tried to the court, which rendered judgment in part for S Co. on its counterclaim, and in favor of K and T on the third-party complaint. On S Co.'s appeal and E Co.'s cross appeal to this court, held: 1. The trial court properly rejected E Co.'s claim that there had been a cardinal change in the contract terms and properly concluded that E Co. breached the contract by abandoning the project: the court properly focused on the nature and impact of the delays on the work expected of and performed by E Co., which were not extraordinary in a pr

What This Ruling Means

**Construction Contract Dispute Results in Mixed Ruling** This case involved a disagreement between two construction companies over electrical work on a hospital expansion project. Semac Electric was hired as a subcontractor by Skanska USA Building to handle all electrical work. The relationship broke down during the project, with both companies claiming the other violated their contract terms. The court found that both companies were partly at fault. Semac Electric wrongfully abandoned the project before completion, violating its contractual obligations. However, Skanska also breached the contract by firing Semac without giving the required 48-hour notice period to fix any problems. The court awarded Skanska $3.8 million in damages for overpayments made to Semac, but also ruled that Semac was entitled to receive some payment based on the percentage of work it had actually completed. **What this means for workers:** This case shows that employment and contractor relationships have legal protections on both sides. Even when one party breaks the rules, they may still be entitled to payment for work already performed. It also demonstrates that companies must follow proper procedures, like giving required notice periods, even when terminating problematic relationships.

This summary was generated to explain the ruling in plain English and is not legal advice.

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The plaintiff appealed from the trial court's judgment granting the defen- dants' motions to dismiss her retaliatory discharge action, which alleged a violation of the whistleblower statute (§ 31-51m). The plaintiff, while employed at a pizza restaurant owned by the defendant S Co. and managed by the defendant L, submitted a complaint to the local health district reporting unsanitary conditions at the restaurant. The day after a health inspector visited the restaurant and disclosed that the plaintiff had made the complaint, the defendants terminated her employment. The plaintiff claimed that the trial court erred in determining that it lacked subject matter jurisdiction on the ground that she had failed to exhaust administrative remedies available through the Department of Labor, as required by § 31-51m (c). Held: The trial court improperly granted the defendants' motions to dismiss the plaintiff's retaliatory discharge action on the ground that it lacked subject matter jurisdiction, as the plaintiff's action focused on her employer's con- duct in terminating her employment following her complaint to the health district, the substance of which related to public health, not occupational safety or health. Argued September 9—officially released December 16, 2025

Remanded

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