Lump sum construction agreements are the most basic of the different design-bid-build options: the contractor agrees to complete the entire scope of work for a fixed price, and assumes most of the quantity and cost risks. If the contractor’s actual costs exceed its estimates, the contractor absorbs the loss. Adding a clause into the construction agreement that allows unit quantities to increase or decrease based on actual job quantities creates a mechanism that can reduce the risk of estimating, but it is a clause that should be carefully drafted and closely guarded.
There are times when it makes sense for parties to deviate from their lump sum agreement and allow for greater flexibility: when there are uncertainties in site conditions or scope, and/or to reduce disputes over changed conditions. The parties can introduce elements of unit-price contracts into the lump sum framework, either choosing to shift the risk entirely to one party or the other, or sharing the risk, e.g., by including an equitable adjustment clause that allows for a price adjustment if the variation exceeds a certain threshold. Even with that balance, incorporating opportunities for adjustments can favor more than just the contractor: it creates a disincentive for the contractor to inflate unit prices to hedge against quantity risks.
Like with any other construction contract, though, if certain items are not thoroughly addressed, it can raise doubts about the resultant risk allocation, breeding an environment ripe for dispute – especially when the quantity differential adds up. This was the case in the conflict giving rise to the action, Providence Construction Corp. v. Silverite Construction Company Inc. et al, 239 A.D.3d 551 (1st Dep’t June 24, 2025).
Plaintiff Providence Construction Corp. subcontracted with defendant Silverite, a general contractor, to perform masonry work on the construction of the Mother Clara Hale Bus Depot, a public infrastructure project for The Metropolitan Transit Authority, acting by The New York City Transit Authority. Providence’s subcontract specified a lump sum payment for furnishing and installing concrete blocks, i.e., concrete masonry units a/k/a “CMU”s, subject to adjustments based on actual job quantities.
During the project’s progression, the parties entered into a change order increasing the quantity of blocks and adjusting the lump sum price to $7,108,873.80. Silverite later noticed, however, discrepancies in its records of the CMUs installed versus those records of Providence. Silverlite paid $5,968,592.01 towards the lump sum price, and withheld payment of $1,140,281.79 on the final three applications.
Providence sued for the difference, and Silverite counterclaimed for $500,000 in damages, alleging overbilling, defective work, delays, and failure to pay vendors. Silverite also filed a third-party complaint against the surety from which Providence procured payment and performance bonds.
Providence moved for summary judgment on liability on its breach of contract claim, to dismiss Silverlite’s counterclaim and to dismiss Silverlite’s third-party complaint. The Supreme Court denied summary judgment in its entirety, and Providence appealed.
The Appellate Division affirmed those portions of the Supreme Court’s decision that denied Providence summary judgment on liability and to dismiss Silverlite’s counterclaim. The Court appreciated that “a fair reading of the subcontract terms as a whole provide for a lump sum payment based upon an estimate of the total number of concrete blocks ‘to be installed’ by plaintiff, and to the extent the actual number installed by plaintiff varied from the ‘estimates,’ the lump sum payment would be adjusted accordingly.” The Court identified issues of fact regarding the actual number of blocks installed and the value of the lump sum price, finding that although Providence had satisfied its burden as a movant by submitting documentary proof in the form of the subcontract and its riders, written correspondences, deposition testimony, and daily business records, Silverite produced credible controverting evidence with its own affidavits and documentary evidence. Most notably, Silverite submitted its expert’s opinion accompanied by architectural drawings, photographs, records kept as to the progress of installation, and the expert’s proprietary 3–D imaging technology showing a different quantity of CMUs that Providence installed. Responding to Providence’s protestations, the Appellate Division stated: “Plaintiff’s arguments that the expert’s methods of computing the number of CMUs laid differed from its own and failed to adequately take into account openings in the building’s interior walls go to the weight and not the admissibility of the expert’s opinion.”
The Court reversed, however, that part of the Supreme Court’s decision that declined to dismiss Silverite’s third-party complaint against Providence’s surety. The Court found that Silverite did not have an interest as a claimant or obligee under the payment and performance bonds because Silverite could not show that it had satisfied the bonds’ default and notice conditions so as to trigger an expectation of coverage.
The Providence decision is an unusual and remarkable public source of constructive takeaways from a construction contract dispute. Putting aside the separate lesson about whether and when a general contractor has a viable claim against a subcontractor’s bond and how to make a proper claim, the decision reflects not only the role of modern technology in fact-dispute resolution, but also how the parties’ subcontract could have been drafted better to avoid their conflict.
From the beginning, the parties agreed that it was uncertain how many concrete blocks would be needed to construct the bus depot. Rather than unfairly place the entire risk on the subcontractor, the parties allowed for a deviation from the then-estimate (of 191,477 total square feet of glazed and regular CMUs combined) and to compensate the subcontractor accordingly. It seems, however, that the subcontract may have lacked a clear mechanism for verifying the final quantities needed from which the subcontractor’s payments would be adjusted. That these parties appeared to use entirely separate verification methods is unfortunate: their agreement could have required the subcontractor to maintain and submit detailed daily logs, installation records, and supporting documentation with each payment application. Their agreement also could have specified acceptable methods of verification, whether the advanced 3D imaging used by the general contractor, or basic field measurements and sampling. Further, their agreement could have included a clause requiring joint measurement or third-party verification of installed quantities at the time of different sections’ completion and prior to finalizing progress payment applications, as well as a clear process for resolving disagreements over quantities or payment, including timelines and escalation procedures.
In sum, on any subject important to a construction contract and particularly one necessary to trigger payment, it is better to include as much specificity as possible and offer parties a path forward in the event of uncertainty – rather than a fertile battlefield that ultimately is favorable to neither.