Contracts

Mediation

A non-binding dispute resolution process where a neutral mediator helps the parties reach a voluntary settlement.

Mediation is a structured negotiation facilitated by a neutral mediator. Unlike arbitration or litigation, the mediator does not impose a decision. The mediator helps the parties identify interests, evaluate strengths and weaknesses, and reach a voluntary settlement. Most construction contracts now require mediation as a precondition to arbitration or litigation. The cost is shared, the time investment is days rather than months, and most construction disputes settle in mediation when both sides come prepared.

The key to productive mediation: come with realistic numbers, a written position statement provided to the mediator in advance, decision-making authority in the room (not "I have to call my partner"), and a willingness to settle for less than the full claim if that closes the matter. Construction-experienced mediators (often retired construction lawyers or judges) are far more productive than generalist mediators. Most AAA, JAMS, and state-bar dispute resolution panels include construction-experienced mediators.

Frequently asked questions

How is mediation different from arbitration?+

Mediation is non-binding facilitation by a neutral. The parties decide whether to settle. Arbitration is binding decision-making by a neutral. The arbitrator imposes a result. Most construction contracts step through mediation first, then arbitration if mediation fails.

How long does construction mediation take?+

Typically a single full-day session, sometimes two. The pre-work (position statements, document exchange, mediator selection) takes 30 to 60 days. Most construction disputes that go to mediation settle in that single session if both sides come prepared.

Is mediation required before arbitration?+

Most modern construction contracts (AIA, ConsensusDocs) require mediation before arbitration or litigation. Some allow either party to skip if the other party has refused to mediate in good faith. Always check the specific dispute resolution clause in the contract.

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