U.S. Court of Appeals Affirmed that Architect Owed No Duty of Care to Contractor for Mold Infestation at Construction Site

RICHMOND, Va. - On Jan. 15, the U.S. Court of Appeals upheld a lower court's dismissal of claims against an architect firm that had allegedly failed to remedy water-damaged conditions that fostered mold infestation at a hotel construction site. RCDI Construction, Incorporated; RCDI Construction Management, Incorporated, Plaintiffs-Appellants, v. Space/Architecture Planning & Interiors, P.A.; G. Carroll Hughes, Defendants-Appellees., No. 01-1676 (U.S. Ct. App. 4th Cir.).

In answer to RCDI Construction's appeal of the lower court's dismissal of tortious interference with contract, unfair competition, and negligence claims, the appeals court found that there was no valid contract upon which interference could be …