Not So Cleaver: Why Merely Referencing a Proposal May Not Incorporate Its Terms

W. Hunter Webb and John Mark Goodman | BuildSmart In construction contracts, proposals, drawings, studies, etc. are often incorporated by reference. A Nebraska federal court recently addressed what language is sufficient to accomplish such incorporation. In Cleaver Brooks Co. v. B&K Mechanical Contractors, LLC, No. 4:23-CV-3243, 2026 WL 2254434 (D. Neb. Aug. 5, 2026), the court… Continue reading Not So Cleaver: Why Merely Referencing a Proposal May Not Incorporate Its Terms