Article Date: 11/08/10

LOWER-TIER SUBCONTRACTOR TOO "REMOTE" FOR PAYMENT BOND PROTECTION

Supreme Court of Delaware

Berlin Steel Construction Company v. Western Surety Company

No. 678, 2009
October 4, 2010

Overview

The Delaware Supreme Court has ruled that a third-tier subcontractor could not recover against a private works payment bond. Applying the same rule used with federal Miller Act bonds, the court said the claimant was too remote.

Background

Berlin Steel Construction Co. was ... Log in to view the full text.

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