Pleading and Trying Quantum Meruit, Cardinal Change, and Fraud Claims in Texas Construction Disputes

The Quantum Realm: Strategies for Pleading and Trying Extra Contractual Claims

By Jack E. Byrom

Written for the 39th Annual Texas Construction Law Conference

In “The Quantum Realm: Strategies for Pleading and Trying Extra Contractual Claims,” Allensworth’s Partner Jack E. Byrom examines three claims often brought alongside breach of contract claims in Texas construction disputes: quantum meruit, cardinal change, and fraud, primarily fraudulent inducement. Presented at the 39th Annual Construction Law Conference in San Antonio in 2026, the paper offers practical considerations for plaintiffs and defendants on pleading, proving, and defending each claim, including how these claims bear on client expectations, mediation, dispositive motions, and trial.

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