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Lincoln Construction Co. v. Property Control & Construction Division of the Department of Administration

Citations: 165 S.E.2d 338; 3 N.C. App. 551; 1969 N.C. App. LEXIS 1618Docket: 681SC405

Court: Court of Appeals of North Carolina; February 5, 1969; North Carolina; State Appellate Court

Narrative Opinion Summary

In the case of Lincoln Construction Company v. The Property Control and Construction Division of the Department of Administration, the North Carolina Court of Appeals examined whether the superior court had jurisdiction over a contract dispute involving a state agency. The plaintiff sought payment under a contract for grading and paving at an airport, claiming jurisdiction under G.S. 143-135.3, which provides a mechanism for contractors to bring claims against state entities after completing construction contracts. The statute is applicable only to contracts involving appurtenances to public buildings. The court determined that the plaintiff's contract did not qualify under this statute as it did not pertain to appurtenances to a building, thus not waiving sovereign immunity. Consequently, the superior court lacked jurisdiction, and the appellate court reversed the lower court's decision overruling the defendant's demurrer. The court found no other statutory provisions waiving the state's sovereign immunity, effectively barring the plaintiff's suit. Judges Brock and Britt concurred with the decision to uphold the demurrer, emphasizing the state's immunity from suit absent an explicit statutory waiver.

Legal Issues Addressed

Interpretation of G.S. 143-135.3

Application: The court interprets G.S. 143-135.3 as not applicable to the plaintiff’s contract, which involves construction not defined as appurtenances to a public building.

Reasoning: The statute in question applies exclusively to contracts for the construction of public buildings and related appurtenances...none of which qualify as appurtenances to a building.

Jurisdiction of Superior Court in State Contract Disputes

Application: The superior court lacks jurisdiction to hear the case as the contract does not fall within the statutory provisions that waive sovereign immunity.

Reasoning: The North Carolina Court of Appeals case...addresses whether the superior court has jurisdiction to hear a contract dispute involving the State.

Sovereign Immunity and State Suability

Application: The defendant, a state agency, contends that it cannot be sued without a statutory waiver of sovereign immunity.

Reasoning: The defendant, a state agency, argues that it cannot be sued unless a statute permits it, in light of the established principle of sovereign immunity.

Waiver of Sovereign Immunity under G.S. 143-135.3

Application: G.S. 143-135.3 does not waive sovereign immunity for the plaintiff's contract, as it does not meet the criteria of being related to appurtenances of public buildings.

Reasoning: Therefore, the contract does not fall under the definition outlined in G.S. 143-135.3.