Case Explained: FinalOpinion in case# 25-2003

Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-07-08

The seventh-circuit affirmed the jury’s award of nominal damages to Black & Veatch Construction, Inc., reversed the district court’s grant of summary judgment regarding The Boldt Company’s claim for wrongful termination, and remanded the case for further proceedings. The appellate court held that the district court did not abuse its discretion in admitting evidence relevant to credibility and damages, allowing expert testimony that was a reasonable elaboration of disclosed opinions, or instructing the jury on nominal damages under Illinois law when the plaintiff failed to provide a reasonable basis for computing costs. The court found no manifest weight of the evidence error in the jury’s conclusion that Black & Veatch failed to prove its damages with sufficient certainty. Regarding the summary judgment reversal, the court applied Illinois contract law and the standard that a contract is ambiguous if it is reasonably susceptible to more than one meaning, requiring a jury to resolve such disputes. The court determined the subcontract was ambiguous regarding whether Boldt was automatically responsible for all delays absent specific notice procedures or whether liability depended on actual fault. Additionally, the court found a material dispute of fact concerning whether Boldt’s written communications adequately notified Black & Veatch of delays caused by site conditions and supplier failures, as required by the agreement. Consequently, the question of whether Black & Veatch had cause to terminate the subcontract must be decided by a jury. The practical consequence is that the case returns to the district court for a new trial on the issue of liability and wrongful termination. The existing jury verdict awarding nominal damages to Black & Veatch remains in effect; if Boldt prevails on the liability question, it may seek damages, but if Black & Veatch proves breach of contract, its damages are limited to the amount already determined by the first jury.

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