1081 Camino v. JDA Associates CA4/1

CourtCalifornia Court of Appeal
DecidedOctober 29, 2025
DocketD083818
StatusUnpublished

This text of 1081 Camino v. JDA Associates CA4/1 (1081 Camino v. JDA Associates CA4/1) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
1081 Camino v. JDA Associates CA4/1, (Cal. Ct. App. 2025).

Opinion

Filed 10/29/25 1081 Camino v. JDA Associates CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

1081 CAMINO, LLC, D083818

Plaintiff and Appellant,

v. (Super. Ct. No. 37-2020- 00047637-CU-PN-CTL) JDA ASSOCIATES, INC., et al.

Defendants and Respondents.

APPEAL from a judgment of the Superior Court of San Diego County, Kenneth J. Medel, Judge. Affirmed. Mazur & Mazur and Janice R. Mazur for Plaintiff and Appellant. Byron Edwards & Lemley, Michael M. Edwards and Zachary M. Lemly for Defendant and Respondent JDA Associates, Inc. Schwartz & Janzen, Noel E. Macaulay and Steven H. Schwartz for Defendant and Respondent Robert Andrew Hernandez. INTRODUCTION At an arbitration on a contract dispute between a commercial building owner and a general contractor, a three-member arbitration panel found in favor of the general contractor. This included the owner’s counterclaims the general contractor was liable to it for damages arising from the general contractor’s mismanagement of design services rendered under a subcontract with architects. The panel specifically found there was no evidence the work performed by the architects “in any way caused financial harm” to the owner. In the owner’s separate lawsuit against the architects in superior court, the trial court granted the architects’ motions for summary judgment, finding the arbitration ruling barred the action under principles of issue preclusion and claim preclusion. We affirm solely on the principle of claim preclusion. We also uphold the trial court’s denial of the owner’s motion to amend the complaint to add fraud claims against the architects. FACTUAL AND PROCEDURAL BACKGROUND I. The Contracts 1081 Camino, LLC (1081 Camino) is the owner of a commercial building located at 1081 Camino Del Rio South in San Diego. In July 2019, 1081 Camino hired WRKB Builders, Inc., dba Online Builders (Online Builders) to act as general contractor to design and construct “certain tenant

improvements” at its building.1 Their contract (Owner-Contractor Contract) provided that Online Builders would “furnish construction administration and management services,” and that it would be “responsible for supervision and coordination” of the work performed pursuant to the contract. The contract allowed Online Builders to subcontract work not performed “with its own forces.” It also contained an arbitration clause.

1 The contract with Online Builders originally identified Solute, Inc. (Solute) as the “owner” but, in October 2019, it was amended to substitute 1081 Camino in place of Solute. (Capitalization omitted.) Because Solute is no longer a party to the underlying litigation and is not a party to this appeal, we do not discuss this entity any further.

2 Online Builders, in turn, subcontracted design services to an architect

named Richard Andrew Hernandez.2 Pursuant to their contract (Architect Services Contract), Hernandez agreed to draft and produce “architectural [c]onstruction [d]ocuments” for 1081 Camino’s “[t]enant [i]mprovement plans for [a] two story office building and parking garage.” He was to also obtain necessary building permits and assist with “[c]onstruction administration” and “plan updates as required by code or [an] inspector.” Hernandez, however, was not yet a registered and licensed architect in California when the Architect Services Contract was signed in August 2019. So he retained a licensed architect, John DeFranza of JDA Associates, Inc. (JDA), to oversee his work and act as the architect of record until he obtained his license in December 2019. II. Arbitration Between Online Builders and 1081 Camino The deal between Online Builders and 1081 Camino fell apart in June 2020. Online Builders submitted a demand for arbitration of its claims to the Construction Tribunal of the American Arbitration Association (AAA), in September 2020. The claims sought payment of unpaid fees and costs for services performed under the Owner-Contractor Contract. 1081 Camino answered and counterclaimed in October 2020. 1081 Camino initially named Hernandez and JDA (together, the architects) as additional respondents to its counterclaim. But in November 2020,

2 We recognize the Civil Code precisely defines and distinguishes between “ ‘[d]esign professional,’ ” “ ‘[d]irect contractor,’ ” and “ ‘[s]ubcontractor’ ” in statutes that regulate the construction industry. (Civ. Code, §§ 8014, 8018, 8046.) Those definitions are not relevant to our analysis. We use the term “subcontract” here in its generic sense to mean a contract that is subordinate to another contract.

3 Hernandez and JDA sent a joint letter to the AAA stating, “We are in receipt of the . . . request to add [us] to the counter claim against [Online Builders]. We reject this request.” Approximately one month later, 1081 Camino voluntarily dismissed the architects without prejudice from the arbitration proceeding and sued them in San Diego County Superior Court. In its operative counterclaim against Online Builders in the arbitration proceeding, 1081 Camino alleged it purchased an office building “with the goal of making improvements . . . to make the site its national headquarters,” and it “hired [Online Builders] specifically to improve th[e] office building and surrounding areas.” “[Online Builders] failed to live up to its responsibilities and duties as [g]eneral [c]ontractor, and breached its duties to exercise reasonable care in the planning, design, and construction administration of [1081 Camino’s] offices, thereby causing [1081 Camino] to suffer over $1 million in construction overage damages and lost revenues, among other damages.” (Italics added.) 1081 Camino alleged in the counterclaim that Online Builders mismanaged the construction project in several ways that did not involve the architects’ services. For example, it alleged Online Builders failed to hire enough workers to complete the project in a timely manner, allowed “obvious hazards and dangerous conditions” on the worksite, failed to pay its subcontractors resulting in mechanics liens on the office building, and overbilled for services it had not yet completed. But 1081 Camino also specifically alleged Online Builders was liable for damages based on the services it had retained Hernandez to provide. In support of its counterclaim, 1081 Camino attached as exhibits both the Owner-Contractor Contract and the Architect Services Contract.

4 In particular, 1081 Camino alleged in the counterclaim that “[u]nder the [Owner-Contractor Contract], [Online Builders] agreed to provide first rate construction services, to complete the [p]roject in accordance with the plans, specifications, and drawings that were supposed to have been completed under the Architect [Services Contract].” But “Online Builders’ handling of its responsibilities regarding the design for the [p]roject has . . . fallen short” and its “work product is below standard.” According to the counterclaim, even after the plans were approved, 1081 Camino “continued to find errors in the architectural plans submitted to the [c]ity for items that were not compliant with applicable building laws, codes, and regulations.” The counterclaim specifically alleged mismanagement by Online Builders on the ground that Hernandez was initially unlicensed and submitted plans to the city that had been stamped and approved by JDA.

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1081 Camino v. JDA Associates CA4/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/1081-camino-v-jda-associates-ca41-calctapp-2025.