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COTTON COUNTY • CJ-2025-00007

Brady White v. Duit Construction Co., Inc.

Filed: Feb 15, 2023
Type: CJ

What's This Case About?

Let’s get one thing straight: this is not a lawsuit about dirt. Oh no. This is a drama about dirt — the kind of dirt that changes landscapes, kills cattle, and allegedly leaves behind a construction site that looks less like a future residential paradise and more like a post-apocalyptic concrete jungle with rebar teeth. Brady White, a landowner in Cotton County, Oklahoma, is suing Duit Construction Co., Inc. not just for taking too much dirt — but for allegedly turning his property into a bovine death trap and then billing the state for the privilege.

So who are we even talking about here? On one side, you’ve got Brady White — a private landowner with roughly five acres that, until recently, was just regular Oklahoma farmland. Nothing flashy, nothing cursed. On the other side: Duit Construction Co., Inc., a full-blown Oklahoma corporation that landed a nearly $17 million contract with the Oklahoma Turnpike Authority to build some stretch of road nobody’s ever heard of (Project HEB-MC-67B, if you’re into bureaucratic poetry). These guys don’t play small — they’ve got project managers, assistant project managers, and apparently, a serious appetite for cubic yards.

Back in August 2022, they made a deal. White would let Duit use his land as a temporary construction site — a “borrow and waste” area, which sounds like a bad indie band but is actually construction jargon for “you can dig here and dump your junk here.” In exchange, Duit would pay him 40 cents per cubic yard of dirt they took — up to 10,000 cubic yards. That’s about $4,000, give or take. Not life-changing money, but hey, free cash for letting trucks rumble across your pasture for a few months. Oh, and there was a bonus: Duit promised to leave the land in a “neat and orderly condition,” build a functional dam out of waste concrete (as shown on Exhibit B — yes, there’s a diagram), and create a pond suitable for future residential development and cattle grazing. White, possibly imagining a serene little lake for his future McMansion compound, signed on the dotted line.

Then… things got wild.

According to White’s petition, Duit didn’t just take 10,000 cubic yards of dirt. They took 72,500. That’s over seven times the agreed amount. And they didn’t dig in the little square marked on the map. Nope. They went rogue, excavating from an entirely different area, reshaping the entire topography like they were sculpting a modern art installation titled “Oops, All Liability.” The landscape, White claims, has been “dramatically” altered — which, when you’re a farmer, is less “art” and more “existential nightmare.”

But it gets worse. Remember that dam they were supposed to build? The one that was supposed to be safe for livestock and future homeowners? Instead of a stable, functional structure, White says Duit left behind a Frankenstein’s monster of jagged concrete chunks with rebar sticking out like metal daggers — the kind of thing that would make a cow say, “Hard pass.” And tragically, at least six of White’s cattle — including three pregnant heifers — were injured or killed after coming into contact with the debris. Let that sink in: pregnant cows died because of poorly dumped construction waste. That’s not just negligence — that’s a country song waiting to happen.

Oh, and Duit didn’t even put the junk where White told them to. The agreement clearly states the waste area had to be at the owner’s direction. Instead, they dumped it wherever they felt like it, forcing White to pay to haul away 60 truckloads of illegal debris himself. Meanwhile, Duit reportedly got paid over $1.6 million by the Oklahoma Turnpike Authority for work done on or related to White’s property — including, presumably, for all that extra dirt they took without permission.

So why are we in court? Legally speaking, White is making two big claims. First: breach of contract and unjust enrichment. Translation: “You broke the deal, took way more than you were allowed, didn’t clean up, and now you’re richer while I’m stuck with a wasteland and dead livestock.” He’s demanding either fair market value for the 62,500 extra cubic yards of dirt (which he estimates at $75,930 total) or at least the original 40-cent rate for the excess — plus cleanup costs. Second: negligence. Basically, “you left dangerous conditions on my land, ignored safety, and caused real harm.” The pond doesn’t work. The dam is a hazard. The land is unusable for development or grazing. And someone — namely Duit — should pay for that.

Now, let’s talk numbers. White is asking for over $75,000 in damages — and yes, that’s a lot of money to most of us. But when you consider Duit allegedly got over a million from the state for work on this exact site, and they only paid White about $10,800 (which already covers more dirt than was agreed upon), $75K starts to look less like a windfall and more like basic accountability. He’s also asking for injunctive relief — meaning he wants the court to force Duit to actually fix the dam and pond the way they were supposed to in the first place. No half-assed concrete graveyard. No more rebar landmines. Just… do the damn job right.

And honestly? This case is a goldmine of petty civil court absurdity. It’s got everything: a land deal gone wrong, a construction company gone rogue, dead pregnant cows, and a dam that looks like it was built by a sleep-deprived intern. The most absurd part? Duit allegedly got paid by the state for work that, according to White, was never completed properly — and now the guy whose land they trashed is the one footing the cleanup bill. It’s like if a plumber came to fix your sink, flooded your entire house, stole your towels, and then got a five-star review from your landlord.

Are we rooting for Brady White? Absolutely. Not because he’s some innocent saint — he did sign a contract that allowed “approximate” dirt removal, which Duit could try to exploit — but because the scale of the alleged overreach is cartoonish. Seven times the dirt? Dead livestock? A dam made of jagged death? And they didn’t even ask where to dump the trash? Come on. If you’re going to dig up someone’s land and promise them a pond, at least deliver a pond — not a liability lawsuit with a side of bovine tragedy.

This isn’t just about dirt. It’s about trust, contracts, and the fact that when big construction companies roll into small towns, sometimes they treat local landowners like afterthoughts. Well, Brady White is saying: “Not so fast.” And if the court agrees, Duit Construction might just learn that in Cotton County, you don’t mess with a man’s dirt — or his cows.

Case Overview

$75,930 Demand Jury Trial Petition
Jurisdiction
District Court, Oklahoma
Relief Sought
$75,930 Monetary
Injunctive Relief
Plaintiffs
  • Brady White individual
    Rep: Kelsey B. Kephart, Kayla D. Dupler of Kephart Law, PLLC, and Kelli J. Goodnight, of Goodnight Law, PLLC
Defendants
Claims
# Cause of Action Description
1 Breach of Contract & Unjust Enrichment Plaintiff alleges Defendant breached their contract and was unjustly enriched by removing more dirt than agreed upon and not leaving the property in a neat and orderly condition.
2 Negligence Plaintiff alleges Defendant was negligent in maintaining hazardous conditions on the property and constructing a dam that was not suitable for use.

Petition Text

1,922 words
IN THE DISTRICT COURT OF COTTON COUNTY STATE OF OKLAHOMA BRADY WHITE, individually, Plaintiff, v. DUIT CONSTRUCTION CO., INC. Defendant. Case No.: CJ-2025-7 PETITION COMES NOW Brady White, Plaintiff, by and through his attorneys, Kelsee B. Kephart and Kayla D. Dupler of Kephart Law, PLLC, and Kelli J. Goodnight, of Goodnight Law, PLLC, and for their cause of action against the Defendants, alleges as follows: 1. Plaintiff, Brady White (hereinafter "White"), is an individual residing in Cotton County, State of Oklahoma. 2. To Plaintiff's knowledge, Defendant, Duit Construction Co., Inc. ("Duit"), is an Oklahoma corporation doing business in Cotton County. 3. To Plaintiff's knowledge, James Duit, is the owner of defendant corporation and is an individual residing in Oklahoma County. 4. To Plaintiff's knowledge, Registered Agent Solutions, Inc., is the registered agent of Duit per the Oklahoma Secretary of State. 5. The underlying subject matter of the contract and/or substantial performance of the contract occurred in Cotton County, State of Oklahoma. 6. Jurisdiction and venue are proper in this county and this Court. Count I: Breach of Contract & Unjust Enrichment 7. Upon information and belief, on or about June 14, 2022, Duit bid on an Oklahoma Turnpike Authority (hereinafter “OTA”) construction project for the amount of $17,123,471.71 and was subsequently awarded the contract. 8. On or about August 16, 2022, White entered into a “Project Site Borrow and Waste Agreement” (Exhibit A, hereinafter “Agreement”) with Duit wherein Duit leased White’s property in order to establish a construction site for a project that Duit was contracted to complete for the OTA. 9. Pursuant to the Agreement, White agreed to lease his property and grant Duit an exclusive right to enter the Site, and all necessary easements appurtenant thereto, including, but not limited to, those for ingress, egress, and utilities, for the purpose of discarding construction waste material, according to certain terms, to take 10,000 cubic yards of dirt, and such other waste and taking as necessary for the road construction process. (Exhibit A, Article 3) 10. Upon information and belief, Duit actually removed approximately 72,500 cubic yards of dirt, over seven times the amount that White originally agreed to, and from an area not agreed to on White’s property (Exhibit C), dramatically changing the landscape and topography of White’s property. 11. Duit agreed to pay White $0.40 per cubic yard of dirt removed for the duration of the Agreement, which was for 10,000 cubic yards of dirt. Duit further agreed to leave the Site in a neat and orderly condition with natural draining (emphasis added), in addition to discard the broken or waste concrete into a pile for the construction of a dam, as indicated on Exhibit B. (Exhibit A, Articles 6 and 4(c)). 12. White has been paid approximately $10,793.20 from Duit for the collected dirt and property use; at $0.40/cubic yard, this paid for roughly 26,982 cubic yards of dirt. However, any amount of dirt removed exceeding 10,000 cubic yards per the Agreement, should be paid to White at the current fair market value (approximately 62,500 cubic yards of dirt actually taken and owed at current fair market value). Alternatively, and at the very least, White is owed $0.40 per cubic yard for the remaining 45,518 cubic yards actually taken and not compensated for. 13. White’s property has not been kept in a “neat and orderly condition” pursuant to the Agreement which has resulted in substantial real and personal property damage; including but not limited to 6 injured and deceased cattle (3 heifers, all carrying offspring). 14. Duit has constructed debris and other hazardous conditions on White’s real property that is inhibiting and hindering the quiet use and enjoyment and further development of White’s real property, specifically further residential development and cattle grazing. 15. Duit left large, jagged pieces of concrete with metal rebar protruding through the pieces and dam overall. 16. Duit further agreed that the location for any discarded construction waste or material would “be at the Owner’s (White) direction.” (Exhibit A, Article 4(a)). 17. White had to remove/pay to have removed 60 loads of discarded concrete, rebar, and other material that was not left in an area/location agreed upon by him, pursuant to the Agreement. 18. Duit further agreed that the removal of the dirt per the Agreement would be from the area notated in the square on Exhibit B (Exhibit A to our Exhibit A). 19. Duit removed dirt without permission and in breach of the Agreement by removing it from the area indicted on Exhibit C instead of the agreed area noted in the original agreement; this has substantially altered the landscape and topography of White’s property. 20. At this time, Duit is believed to have been paid approximately $1,605,530.00 by the OTA for the portion of the construction project related to White’s real property, including dirt removed. As such, Duit has been unjustly enriched at White’s expense. 21. White was led to believe and relied on the representation that the final product of Duit’s activities would result in a functional pond (from dirt removal) and dam (using construction waste and material) (see Exhibit B) that would be safe and usable for further residential development and livestock grazing. 22. Duit was made aware of the intended use of White’s real property for future residential development and immediate livestock grazing. 23. The current conditions of the dam and discarded materials are not suitable nor safe for White’s livestock. 24. The current conditions of the dam and discarded materials are not suitable nor safe for human use as a common area in a residential development. 25. The pond and dam constructed by Duit are not functional for the intended uses by the White that were known to Duit and have devalued White’s property overall. 26. The pond constructed by Duit, not in accordance with the Agreement, needs to be filled and reconstructed. 27. The dam constructed by Duit, not in accordance with the Agreement, needs to be removed, hauled off, and reconstructed. Count Two: Negligence 28. White reasserts the above allegations and specifically asserts that Duit was negligent by maintaining such hazardous conditions and in their construction of the dam in question. White has suffered actual harm to his real and personal property as a result of Duit’s negligence. WHEREFORE, Petitioner demands payment of damages in excess of $75,000.00; interest for the entire sum accrued and accruing; attorney’s fees and costs for the current action accrued and accruing; alternatively injunctive relief for the removal of the hazardous conditions and construction of the dam and pond as described in the Agreement; and any other relief the Court may deem just and proper. Respectfully submitted, Kelsey B. Kephart, OBA #34160 Kayla D. Dupler, OBA #34143 Kephart Law, PLLC 802 SW D Ave. Lawton, OK 73501 Phone: 580.606.6896 Email: [email protected] Attorneys for Brady White ATTORNEY LIEN CLAIMED JURY TRIAL DEMANDED Project Site Borrow and Waste Agreement This Project Site Borrow and Waste Agreement ("Agreement") is between Duit Construction Co., Inc. ("Company") and Brady White ("Owner") (collectively the "Parties"). In consideration of the mutual covenants hereinafter set forth, Company and Owner agree as follows: 1. Lease of the Property. The Owner leases to the Company a portion of the real property described as S20 T2S R11W W2 SW, Cotton County, Oklahoma, comprising an area of roughly 5 acres and diagramed on the Google Earth image attached as Exhibit A, and incorporated by reference (the "Site"). 2. Purpose. The purpose of this agreement is for the Company to establish a Site for use during the construction of Project Number HEB-MC-67B with the Oklahoma Turnpike Authority (the "Construction Project"). 3. Easements. The Owner grants the Company an exclusive right to enter the Site, and all necessary easements appurtenant thereto, including, but not limited to, those for ingress, egress, and utilities, for the purpose of discarding construction waste material, to take 10,000 cubic yards of dirt, and such other waste and taking as necessary for the road construction process. 4. Property Conditions. The Company agrees to keep the site free of all loose trash and debris. The Company shall provide any utilities required at its expense. The Owner leases the property in an "as is" condition at the commencement of this Agreement. a. Company will use the Site for the purpose of discarding construction waste material, and such other waste necessary for the road construction process. The location of the waste area shall be at the Owner's direction. b. The Company leases the Site in an "as is" condition. c. The Company will leave the Site in a neat and orderly condition with natural drainage. d. Other noted conditions (none if blank): the total number of cubic yards removed is approximate and may exceed the amount stated above. The Company will discard the broken or waste concrete into a pile for the construction of a dam, as indicated on Exhibit A. 5. Term; Termination. The term of this Agreement will begin on the signing date and terminate when the Company has concluded its operations and has satisfied the terms of this Agreement, but no later than 30 days after final acceptance of the Construction Project by the project owner. Upon the Termination of this Agreement, the Company shall remove all equipment and materials and surrender the Site to the Owner in the condition stated in Section 3 of this Agreement, ordinary wear, tear, and acts of God excepted. 6. Rental Payments. The Company agrees to pay the Owner the amount of $0.40 per cubic yard removed for the duration of this Agreement. The Company will pay for the first 1 month's lease when the Owner signs this Agreement. The Company will pay the monthly payments by the 15th of each month beginning on the Choose an item. month and continuing for each month Company wishes to use the property. 7. Warranties of Owner. The Owner represents that their ownership of the Site is fee simple and absolute. Owner shall provide Company with proof of ownership upon request. 8. Damage to the Site; Eminent Domain. If an act of God damages the Site or renders its use by the Company impracticable, or if all or a portion of the Site is taken by eminent domain, or it for any reason the Site is rendered inoperable for more than thirty days by any government action, Company may, with 10 days advance written notice, terminate this Agreement by notifying Owner in writing. 9. Assignment. The Company may assign, pledge, or otherwise transfer its rights or obligations under this Agreement with the prior written consent of the Owner. Assignment of this Agreement shall not release Company from its performance of any of the covenants in this Agreement. 10. Notices. Any notice or communication concerning this Agreement shall be sent by certified mail, return receipt requested, or delivered by hand, to the Parties at the respective addresses below. 11. Hold harmless. The Company shall hold the Owner harmless from any liability concerning Company’s operations during this agreement. 12. Miscellaneous. a. Time is of the essence in this Agreement. b. This Agreement may not be changed or amended except by a written instrument executed by both parties. c. This Agreement shall be binding upon heirs, successors, administrators, and assigns of both parties. d. This Agreement is contingent on acceptance by the construction project owner and that the construction project owner and Company enter into a project agreement. This Agreement is mutually and equally beneficial to both parties and shall constitute the entire Agreement. Executed by Owner and Company through their duly authorized representatives this 16th day of August, 2022. Owner Brady White Duit Construction Co., Inc. Logan Walling, Assistant Project Manager P.O. Box 3788 Edmond, OK 73034 Exhibit A Project Site Waste Agreement Form no. POLID-269924966-1762 Exhibit A Project Site Waste Agreement Form no. POLID-269924966-1762 Photo Borrow Area Dam
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