American Continental Life Insurance Co. v. Ranier Construction Co., Inc.

American's (defendant) construction contract with Ranier (plaintiff) conditioned final payment on Ranier obtaining a final payment certificate from the architect, a requirement both parties consistently followed throughout the project even though they didn't always strictly follow separate procedures for change orders and time extensions; at the end of the project, American rejected the architect's punch list and Ranier never obtained the final certificate, yet the jury awarded Ranier damages for the unpaid final payment anyway.