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TULSA COUNTY • CJ-2025-46

Todd Carrico v. JAG Buildings, LLC

Filed: Jan 3, 2025
Type: CJ

What's This Case About?

Let’s cut straight to the drama: a man paid a contractor to pour a concrete slab for his new building, and now he’s suing for $150,000—$75,000 for breach of contract, another $75,000 for breach of warranty—because the slab is so poorly done that engineers are saying, “Just tear it out and start over.” This isn’t a crack here or there. This is a full-scale structural facepalm. And the contractor? According to the filing, they won’t even show up to look at it. That’s like a chef refusing to taste the soup after you tell him it’s made of motor oil.

So who are these people? On one side, we’ve got Todd Carrico, a regular homeowner (or small property developer, hard to say) living in Tulsa County, Oklahoma, trying to build a 40x60-foot building—probably a shop, garage, or maybe a hobby barn—out in Skiatook, which is basically where the city ends and the cows begin. He’s not some corporate entity. He’s a guy with a property, a dream, and a checkbook. On the other side: JAG Buildings, LLC, a local construction company that, based on the name, probably specializes in metal buildings, slabs, and turnkey structures. They’re not some fly-by-night operation—registered in Oklahoma, based in Tulsa County, and presumably have done this before. But somewhere between March 2024 and January 2025, things went from “Let’s build a building” to “Let’s build a lawsuit.”

Here’s how it all went sideways. On March 4, 2024, JAG sent Todd a written quote—what they call a “Purchase Agreement/Quote”—for the construction of the building, including the concrete slab. Todd signed it. Boom: contract formed. No handshake, no “trust me, bro,” just a signed document. That’s important. Because when things go wrong, paper doesn’t lie. JAG was supposed to pour a concrete slab—4 inches thick, with rebar properly placed. Standard stuff. Not rocket science. Not art. This is like the “grilled cheese sandwich” of construction: simple, but if you mess it up, you’ve got no business cooking.

But according to Todd, JAG didn’t just mess it up. They nuked it. The slab? Less than 4 inches thick in places. The rebar? Not where it’s supposed to be. When you skimp on rebar placement or pour thin concrete, you’re not just cutting corners—you’re inviting cracks, settling, and eventual collapse. It’s like building a bridge out of soda crackers. And this isn’t Todd just being picky. He brought in 360 Engineering Group, PLLC—a legit engineering firm—to assess the damage. And their verdict? “Remove and repair.” Not “patch it.” Not “add some epoxy.” Tear it out and start over. That’s the construction equivalent of a doctor saying, “We’re gonna have to amputate.”

Now, tearing out and replacing a 2,400-square-foot concrete slab isn’t cheap. But that’s not even the worst part. Because the building was already framed, and electrical and plumbing were installed on top of the slab. So now, to fix the foundation, Todd has to rip out framing, rework electrical, redo plumbing, and then pour a new slab. It’s a domino effect of disaster. And according to the petition, the total cost? Over $75,000. That’s not a typo. Seventy-five grand to fix what should’ve been a routine pour.

So why is Todd in court? Two reasons, both wrapped in legal packaging but easy to unpack. First: breach of contract. You agreed to do a job. You didn’t do it right. That’s breach. Simple. JAG promised a 4-inch slab with proper rebar. They delivered a substandard slab. That’s not a misunderstanding. That’s a failure to perform. Second: breach of warranty. The contract included a one-year warranty on labor and workmanship—standard in construction. But when Todd raised the red flag, JAG allegedly ghosted him. No inspection. No fix. No “Hey, we’ll make it right.” Just radio silence. And in legal terms, that’s not just rude—it’s a breach of the warranty. You can’t offer a warranty and then refuse to honor it. That’s like selling a phone with a “one-year screen replacement guarantee” and then ignoring every call after the screen cracks.

Now, let’s talk money. Todd is asking for $75,000 on the contract claim and another $75,000 on the warranty claim—totaling $150,000 in damages. But wait—the relief sought section says he’s only demanding $75,000 in monetary damages. Huh? Here’s the twist: in the “WHEREFORE” clause (that’s lawyer-speak for “here’s what I want”), Todd asks for $75k on each claim. But legally, you can’t double-dip. You can’t get $75k for breach of contract and another $75k for breach of warranty for the same damages. The court isn’t going to hand you two checks for the same busted slab. So the $150,000 is likely a legal tactic—pleading in the alternative, in case one claim fails. But the real ask? $75,000 to cover the actual costs: demolition, rework, engineering fees, legal bills. And honestly? For a full structural redo, that’s not outrageous. A new slab alone could cost $10–$15 a square foot—that’s $24,000 to $36,000 just for concrete. Add in labor, rework on framing and utilities, engineering reports, legal fees, and yeah—$75k starts to look… reasonable. Painful, but reasonable.

So what’s our take? The most absurd part isn’t even the bad concrete. It’s the ghosting. You’re a contractor. You have a warranty. A client says, “Your work failed.” And your response is… nothing? Not “We’ll send a crew.” Not “Let’s assess it.” Not even “We deny liability.” Just crickets? That’s not just bad business. That’s a one-way ticket to lawsuit city. And look, we’re not saying every contractor has to fix every problem. Maybe JAG thinks the slab is fine and the engineer is overreacting. Maybe Todd moved sprinkler lines or overloaded the slab. But you don’t win that argument by ignoring it. You win it by showing up. By inspecting. By engaging. By acting like a professional.

We’re rooting for Todd, not because he’s flawless, but because he followed the playbook: he hired a pro, got it in writing, brought in an engineer when things went south, and now he’s using the legal system to demand accountability. And we’re side-eyeing JAG, not because one job went bad—stuff happens—but because their alleged refusal to even look at the problem makes it feel less like a mistake and more like a pattern. If this is how they handle warranty claims, God help their other clients.

At the end of the day, this isn’t really about concrete. It’s about trust. Todd trusted JAG to do a basic, fundamental part of a building. They failed. And then, instead of fixing it, they vanished. That’s not just a breach of contract. That’s a breach of common decency. And in the wild world of petty civil court drama, that’s the kind of behavior that earns you a $75,000 lesson in accountability. Pour the concrete right, or pay for it later—literally.

Case Overview

$150,000 Demand Petition
Jurisdiction
Tulsa County District Court, Oklahoma
Relief Sought
$75,000 Monetary
Plaintiffs
Defendants
Claims
# Cause of Action Description
1 Breach of Contract Plaintiff alleges Defendant breached contract for failing to perform work required under the contract.
2 Breach of Warranty Plaintiff alleges Defendant breached warranty of labor and workmanship for failing to install concrete slab properly.

Petition Text

574 words
IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA TODD CARRICO, an individual, Plaintiff, vs. JAG BUILDINGS, LLC, an Oklahoma Limited liability company, Defendants. CJ-2025-00046 Case No. Judge ATTORNEYS' LIEN CLAIMED DISTRICT COURT FILED JAN 03 2025 DON NEWBERRY, Court Clerk STATE OF OKLA. TULSA COUNTY PETITION FOR BREACH OF CONTRACT AND BREACH OF WARRANTY COMES NOW Plaintiff Todd Carrico ("Carrico") and for his causes of action against Defendant JAG Buildings, LLC("JAG"), alleges and states as follows: 1. Plaintiff is a resident of Tulsa County, State of Oklahoma. 2. JAG is an Oklahoma limited liability company with its principal place of business in Tulsa County, State of Oklahoma. 3. Plaintiff contracted with JAG construct a building with concrete at 4948 W. 165th St. N., Skiatook, Oklahoma. 4. Venue and jurisdiction are proper in this Court. FIRST CAUSE OF ACTION BREACH OF CONTRACT 5. Plaintiff realleges and incorporates paragraphs 1-4. 6. On or about March 4, 2024, JAG provided Plaintiff with a written "Purchase Agreement/Quote" for the construction of a 40x60 building with concrete. A contract was formed between Plaintiff and JAG when Plaintiff signed the estimate in acceptance of its terms on or about March 4, 2024. 7. JAG breached the contract by failing to perform the work required under the contract, specifically, the concrete slab is deficient and does not meet specified 4” thickness and the rebar is not placed correctly. 360 Engineering Group, PLLC has recommended that the slab be removed and repaired. 8. JAG’s actions have damaged the property and caused necessary repairs, rework electrical, plumbing, framing and replacement concrete in an amount in excess of $75,000.00. In addition, Plaintiff has incurred professional fees and expenses in order to assess the damage. 9. Plaintiff is entitled to judgment against JAG for breach of contract in the amount of $75,000 plus pre-judgment and post-judgment interest, costs, and attorney’s fees. SECOND CAUSE OF ACTION BREACH OF WARRANTY 10. Plaintiff realleges and incorporates paragraphs 1-9. 11. The contract between Plaintiff and JAG contained an express warranty of labor and workmanship for a period of one (1) year. 12. JAG breached the warranty of labor and workmanship by failing to install the concrete slab properly. JAG has failed to honor the warranty. JAG has refused to visit the property or to even inspect the slab. 13. Plaintiff has suffered damages as a result of JAG’s breach of warranty. 14. Plaintiff is entitled to judgment against JAG for breach of warranty of workmanship in the amount of $75,000.00 plus pre-judgment and post-judgment interest, costs, and attorney’s fees. WHEREFORE, premises considered, Plaintiff requests judgment in its favor and against JAG on its breach of contract claim in the amount of $75,000.00, and judgment in its favor against JAG on its breach of warranty claim in the amount of $75,000.00; plus pre-judgment and post-judgment interest, and costs and attorney's fees, and for any such additional relief as the Court deems just and equitable. Respectfully submitted, BARROW & GRIMM, P.C. James R. Hicks, OBA #11345 110 W. 7th, Suite 900 Tulsa, OK 74119 Telephone: 918-584-1600 Facsimile: 918-585-2444 [email protected] COUNSEL FOR PLAINTIFF VERIFICATION PURSUANT TO 12 O.S. §426 I state under penalty of perjury under the laws of Oklahoma that I am the Petitioner in the above-entitled action; that I have read the above and foregoing PETITION, and I believe that the facts and matters therein set forth are true and correct. Dated: January 2nd, 2025 in Tulsa, Oklahoma. Todd Carrico, Plaintiff SUBSCRIBED AND SWORN to before me this 2nd day of Jan, 2025. Jody Acosta Notary Public My Commission Expires: 07 02 2017 My Commission Number: 19004400
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