Rojas Concrete v. Flood Testing Laboratories

Conrete subcontractor company sued concrete testing company for negligently testing concrete it had poured at UIC construction site, claiming monetary losses for subcontractor being required to remove concrete by UIC. Court properly dismissed complaint, as Plaintiff failed to allege a duty owed it by Defendant, and the voluntary undertaking doctrine, which generally requires a showing of bodily harm, does not extend to purely economic losses. (NEVILLE and MURPHY, concurring.)