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What Is the Spearin Doctrine in Construction Law?

As a construction law firm, we thought it would be interesting to use our inaugural blog post to write about one of the most important construction litigation cases that continues to have an influence on case law today.

The Spearin Doctrine

We'll kick off our blog with an introduction of one of the fundamental laws regarding liability between contracting agents in a construction contract.

In 248 U.S. 132 (1918), the Supreme Court of the United States (SCOTUS) ruled that when a property owner provides plans and blue prints to a contractor for the construction of a building, the owner is, in essence, providing an implied warranty that the design, materials and construction specifications will meet the requirements for adequate construction. In effect, the court ruled that general contractors will not be held liable for construction defects if they meet the plan specs.

A brief summary of the case

This case involved the U.S. government's Brooklyn Navy Yard contracting with general contractor Spearin to build a dry dock, which required relocating an existing sewer line intersecting the excavation area. After some agreed-upon changes to the original plans, Spearin moved forward with construction according to specifications.

Problems began about a year later, when a heavy rain caused flooding of the area under excavation. The water in the area became backed up due to an unknown dam that had been built in two nearby city sewer systems, both of which were outside the area specified in the construction plans and contract.

The arguments

Spearin notified the government that the flooding at the worksite made continuation of the work impossible. Accordingly, the contractor ceased all further work on the site. The Navy, however, demanded that it was Spearin's contractual obligation to remediate the problem and continue to work until the project was completed, per terms of the contract. Spearin refused to continue and the Navy eventually annulled the contract and took control of the materials remaining on site.

At the point the contract was annulled, Spearin had been paid nearly $130,000 of the $210,000 he claimed for expended costs. He sued the Navy for the remaining money owed, plus legal costs necessary for recovery, arguing that the plans provided by the Navy had not said anything about the offsite sewer system that would require remediation. He initially lost his case in the New York Federal District Court, as well as the U.S. Court of Appeals.

The Navy argued, in turn, that per earlier SCOTUS rulings (Christie v. United States, 237 U. S. 234; Hollerbach v. United States, 233 U. S. 165, and United States v. Stage Co., 199 U. S. 414199 U. S. 424) Spearin had the responsibility to visit the site to review the plans against the reality of the work requirements.  

The SCOTUS ruling establishing the Spearin Doctrine

Spearin brought his appeal to the U.S. Supreme Court and won on the following points of law:

  • "If the contractor is bound to build according to plans and specifications prepared by the owner, the contractor will not be responsible for the consequences of defects in the plans and specifications." MacKnight Flintic Stone Co. v. The Mayor, 160 N.Y. 72; Filbert v. Philadelphia, 181 Pa. 530; Bentley v. State, 73 Wis. 416. See Sundstrom v. New York, 213 N.Y. 68.
  • "The responsibility of the owner is not overcome by the usual clauses requiring builders to visit the site, to check the plans, and to inform themselves of the requirements of the work."

Watch for further blog posts relating to important construction law cases. To learn more, we invite you to visit our main website.

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