Alabama Board of Heating, Air Conditioning, and Refrigeration Contractors v. Elijah Blanchard (Appeal from Jefferson Circuit Court: CV-20-901357).

CourtCourt of Civil Appeals of Alabama
DecidedJuly 12, 2024
DocketCL-2023-0795
StatusPublished

This text of Alabama Board of Heating, Air Conditioning, and Refrigeration Contractors v. Elijah Blanchard (Appeal from Jefferson Circuit Court: CV-20-901357). (Alabama Board of Heating, Air Conditioning, and Refrigeration Contractors v. Elijah Blanchard (Appeal from Jefferson Circuit Court: CV-20-901357).) is published on Counsel Stack Legal Research, covering Court of Civil Appeals of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Alabama Board of Heating, Air Conditioning, and Refrigeration Contractors v. Elijah Blanchard (Appeal from Jefferson Circuit Court: CV-20-901357)., (Ala. Ct. App. 2024).

Opinion

Rel: July 12, 2024

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is published in Southern Reporter.

ALABAMA COURT OF CIVIL APPEALS SPECIAL TERM, 2024 _________________________

CL-2023-0795 _________________________

Alabama Board of Heating, Air Conditioning, and Refrigeration Contractors

v.

Elijah Blanchard

Appeal from Jefferson Circuit Court (CV-20-901357)

HANSON, Judge.

The Alabama Board of Heating, Air Conditioning, and

Refrigeration Contractors ("the Board") appeals from a judgment entered

by the Jefferson Circuit Court ("the circuit court"). In that judgment, the

circuit court overturned decisions of the Board revoking Elijah CL-2023-0795

Blanchard's certification to operate as a heating and air-conditioning

contractor.

I. Facts and Procedural History

Blanchard was issued a license by the Board to operate as a heating

and air-conditioning contractor. In 2017, Blanchard was disciplined by

the Board for improper work on a customer's heating and air-conditioning

system and was subjected to sanctions including a fine and mandatory

attendance of a remedial class. Subsequently, Blanchard had two cases

before the Board, resulting in the cases before the circuit court: case

number CV-20-901357 and case number CV-22-903693.

A. Case Number CV-20-901357

On March 21, 2019, Stephen Gatti filed a consumer complaint with

the Board, alleging that A & E Service Company, which was operated by

Blanchard, had improperly installed a heating, ventilation, and air-

conditioning ("HVAC") system. Specifically, Gatti alleged:

"A & E Service Company was sent by a[n] American home warranty company to make repairs. The owner, Elijah [Blanchard], stated that I needed to replace my unit. He helped me get in the Alabama Power Company financing program. He improperly installed the unit, and it caused a new energy efficient unit to perform worse than a 30-year-old unit. Alabama Power sent two experts to conduct an installation inspection and it failed inspection by both

2 CL-2023-0795

experts. I've given the company multiple attempts to correct things, but they have not. The company conducted work during non-business hours, 7 p.m.- 9:30 p.m., and in many cases failed to show up for appointments. Alabama Power has the contract, payment information, and reports of increased power usage. They may also be able to provide the findings of their expert inspections."

On April 12, 2019, Matthew Feld filed a consumer complaint with

the Board, alleging the following:

"I referred and hired Elijah [Blanchard] to my homebuilder who we have worked with on other projects. [Blanchard] was hired to do a complete system for a full remodel. After the last bit of work he did and the lack of professionalism by his staff, I decided to call my previous HVAC [company] if I had issues. The [air conditioning] quit working last week and I placed a service call with Brown Heating and Cooling. Their [technician] arrived and was here for several hours documenting and identifying multiple issues on our 'fully new system.' After inspection, the owner of Brown Heating and Cooling called me and advised based on the amount of issues and the fact this system was just installed my best course of action was to file a complaint as there are several thousand dollar[s'] worth of 'redo' work that needs to be done to bring this system up to code and as it should be for the almost [$10,000] we paid for it. A few of the issues -- duct work not up to code, unit not fully sealed with duct work, coolant leaks already due to the wrong size piping, electrical wiring not up to code."

3 CL-2023-0795

On September 10, 2019, the Board issued a summons and

administrative complaint1 outlining deficiencies in Blanchard's or his

employees' work on the two consumers' HVAC systems. The

administrative complaint alleged that Blanchard had violated § 34-31-18

et seq., Ala. Code 1975, and Chapter 440-X-5 of the Alabama

Administrative Code (Heating, Air Conditioning, and Refrigeration

Contractors Board) ("HACR"). The administrative complaint set forth

with specificity the "life safety" violations and "minimum standard"

violations that Blanchard was alleged to have violated.2

1An administrative complaint is defined under the Alabama Administrative Code (Heating, Air Conditioning, and Refrigeration Contractors Board), r. 440-X-6-.01(3) as "[a] legal document which contains notice of the time and place of an administrative hearing; contains a statement of the charges against the certified contractor; and complies with the notice provisions for contested cases as set forth in the Alabama Administrative Procedure[] Act[, §41-22-1 et seq., Ala. Code 1975]."

2"Minimum standard" is defined under r. 440-X-5-.01(1), Ala. Admin. Code (HACR), as "[t]he basic or minimum requirements allowable by the Board as it pertains to the installation, service, and repair of residential and commercial heating and air conditioning, and commercial refrigeration equipment."

Neither §§ 34-31-18 through 34-31-35, Ala. Code 1975, nor the Board's administrative regulations, rr. 440-X-1 through 440-X-6, Ala. Admin. Code (HACR), contain a definition of "life safety." When a term is not defined in a statute, the commonly accepted definition of the term 4 CL-2023-0795

At the hearing on October 16, 2019, the Board’s investigators

testified regarding 6 life-safety violations and 8 minimum-standard

violations from Blanchard's HVAC installation at Gatti's house, and 6

life-safety violations and 25 minimum-standard violations from

Blanchard's HVAC installation at Feld's house.

Blanchard testified that he had been served with the summons and

administrative complaint pertaining to the Gatti HVAC installation.

Blanchard said that his senior technician had performed the work at the

Gatti installation. Blanchard admitted that the technician had not

properly installed the HVAC system. Blanchard said that after Gatti had

called him to complain, he had sent the technician back to Gatti's house

to make repairs. After Gatti had contacted Alabama Power to complain,

Blanchard said, he returned to Gatti's house. Gatti would not allow

Blanchard to fix the problems with the system. Subsequently, Blanchard

said, he realized that the technician had had a drug problem, and he

terminated the technician's employment. Blanchard presented evidence

that the technician had also stolen Blanchard's work van.

should be applied. Ex parte City of Millbrook, 304 So. 3d 202, 206 (Ala. 2010). Applying this general rule of construction to "life safety," those violations would include violations posing a risk of life or public safety. 5 CL-2023-0795

Blanchard testified that he had been served with the summons and

administrative complaint pertaining to the Feld HVAC installation. He

said that Feld had never contacted him regarding problems with the

HVAC installation. Blanchard said that Feld had contacted him when

the underside of Feld's house had flooded in January 2019. Blanchard

said that he had gone underneath the house and that the furnace had

been in good condition.

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Alabama Board of Heating, Air Conditioning, and Refrigeration Contractors v. Elijah Blanchard (Appeal from Jefferson Circuit Court: CV-20-901357)., Counsel Stack Legal Research, https://law.counselstack.com/opinion/alabama-board-of-heating-air-conditioning-and-refrigeration-contractors-alacivapp-2024.