Joint ventures are a useful means for contractors to spread risk on large-scale infrastructure projects, but a recent U.S. Court of Appeals for the Eleventh Circuit decision highlights the difficulties that arise when joint venturers’ interests diverge. On April 15, 2026, the court decided Lane Construction Corporation v. Skanska USA Civil Southeast, Inc.,[1] addressing whether a joint venture’s managing member breached its fiduciary duty of loyalty by declining to pursue an exit strategy favored by another member. The court held it did not, and separately affirmed that the dissenting member’s refusal to fund capital calls constituted a material breach of the joint venture agreement.