AMF Bruns America, L.P. v. Vantage Mobility International, L.L.C.

CourtDistrict Court, N.D. Ohio
DecidedMay 31, 2024
Docket5:23-cv-01634
StatusUnknown

This text of AMF Bruns America, L.P. v. Vantage Mobility International, L.L.C. (AMF Bruns America, L.P. v. Vantage Mobility International, L.L.C.) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
AMF Bruns America, L.P. v. Vantage Mobility International, L.L.C., (N.D. Ohio 2024).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

AMF BRUNS AMERICA, L.P., ) CASE NO. 5:23-cv-1634 ) ) PLAINTIFF, ) JUDGE SARA LIOI ) vs. ) ) MEMORANDUM OPINION ) AND ORDER VANTAGE MOBILITY ) INTERNATIONAL, L.L.C., ) ) ) DEFENDANT. )

Before the Court is the motion for partial judgment on the pleadings and partial summary judgment of plaintiff AMF Bruns America, L.P. (“AMF”). (Doc. No. 26 (Motion).) Defendant Vantage Mobility International, L.L.C. (“VMI”) did not file an opposition. For the reasons discussed herein, the motion is GRANTED as it relates to liability, DENIED as it relates to VMI’s mitigation defense. I. BACKGROUND AMF filed its original complaint on August 23, 2023 (Doc. No. 1 (Original Complaint)) and filed an amended complaint on August 28, 2023. (Doc. No. 5 (Amended Complaint).) In the amended complaint, AMF alleges that it entered into a series of contracts with VMI for the production and delivery of “specialized equipment” for “wheelchair securement systems for the safe transportation of people with limited mobility[.]” (Id. ¶¶ 1, 18.) AMF alleges that the parties’ transactions followed a straightforward pattern: VMI sent purchase orders to AMF, AMF responded with a corresponding sales order, the products were manufactured and shipped (or, at a minimum, materials were purchased for those orders), AMF provided an invoice, and VMI was obligated to pay within thirty days. (Id. ¶¶ 15–23.) Over the course of roughly nine months, VMI ordered “thousands of products from AMF[,]” seemingly without issue. (Id. ¶¶ 15, 19.) Then VMI stopped paying. (Id. ¶ 24.) It admits as much. (Doc. No. 8 (Answer) ¶ 24 (admitting it failed to pay AMF, but contesting “the total amount of damages” requested by the amended complaint).) For a time, AMF continued to ship products to VMI despite its non-

payment. (Compare Doc. No. 5 ¶¶ 29–30 (alleging VMI’s first missed payment was on February 19, 2022) with id. ¶¶ 45, 47, 51, 53 (alleging AMF shipped products to VMI for purchase orders it received on May 13, 2022).) When VMI’s debts continued to go unpaid, however, AMF stopped shipping orders and retained the materials it purchased for those orders. (Id. ¶¶ 66–67.) As of July 6, 2023, AMF alleges that it has not been paid for an enumerated list of products it shipped and for materials that it purchased for VMI’s open purchase orders.1 (Id. ¶¶ 24, 67.) Additionally, AMF alleges that it could not “resell or repurpose this product without significant effort and expense, and an unlikely return on that investment.” (Doc. No. 26-1, at 9.) Whether AMF took any remedial action for the non-shipped goods is unclear at this stage of the proceedings. (See generally id.)

On April 4, 2024, AMF filed two related motions. AMF filed the present motion, which seeks partial judgment on the pleadings establishing VMI’s liability for products AMF has already shipped to VMI and partial summary judgment foreclosing VMI from raising its mitigation defense

1 The terms of sale, which AMF claims each VMI order is subject to (Doc. No. 5 ¶ 18), contains a limitations provision requiring that “[a]ny action for . . . breach of contract . . . must be commenced within one (1) year after the cause of action has accrued[.]” (Doc. No. 1-1 (Terms of Sale), at 4.) Under Ohio law, limitation provisions within contracts for the sale of goods that are not less than year are generally permissible. See Ohio Rev. Code § 1302.98(A). Further, a breach of contract cause of action “accrues when the breach occurs[.]” Ohio Rev. Code § 1302.98(B). VMI did not raise the contractual limitations period as an affirmative defense in its answer. (See generally Doc. No. 8.) And it did not raise this argument, or any argument, in opposition to AMF’s present motion. Given the lack of notice provide to AMF regarding any timeliness concerns, the Court will not consider this argument sua sponte. Cf. Annette v. Haslam, No. 3:18-cv-1299, 2020 WL 2520512, at *2 (M.D. Tenn. May 18, 2020) (citation omitted) (“[A]lthough a statute of limitations defense is an affirmative defense that ordinarily must be raised by a defendant, the defense may nonetheless be raised sua sponte by the Court in circumstances when it clearly applies and when the plaintiff is put on notice that the timeliness of his or her claims is at issue.”). in future proceedings.2 (Doc. No. 26.) The other motion filed by AMF sought for the first motion to be considered earlier than originally outlined in the case management plan trial order (Doc. No. 12) and with an expedited briefing schedule. (Doc. No. 25 (Scheduling Motion).) VMI filed a response to AMF’s scheduling motion, not opposing the Court’s proposed expedited briefing schedule. (Doc. No. 27.) As stated above, VMI did not file an opposition to AMF’s motion for

partial judgment on the pleadings and partial summary judgment. The matter is now ripe for the Court’s consideration. II. STANDARD OF REVIEW Beginning with the portion of AMF’s motion seeking judgment on the pleadings, under Rule 12(c), a party may move for judgment on the pleadings “[a]fter the pleadings are closed— but early enough not to delay trial[.]” Fed. R. Civ. P. 12(c). The standard of review for a motion for judgment on the pleadings is the same as for a motion to dismiss for failure to state a claim under Fed. R. Civ. P. 12(b)(6). E.E.O.C. v. J.H. Routh Packing Co., 246 F.3d 850, 851 (6th Cir. 2001) (citing Grindstaff v. Green, 133 F.3d 416, 421 (6th Cir. 1998)). “[A]ll well-pleaded material

allegations of the pleadings of the opposing party must be taken as true, and the motion may be granted only if the moving party is nevertheless clearly entitled to judgment.” Poplar Creek Dev. Co. v. Chesapeake Appalachia, L.L.C., 636 F.3d 235, 240 (6th Cir. 2011) (citation omitted). “A complaint need not contain ‘detailed factual allegations.’ But it must ‘contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.’” LM Ins. Corp. v. Criss for Estate of Szuhay, 716 F. App’x 530, 533 (6th Cir. 2017) (first quoting Bell Atl.

2 Although not explicitly stated in AMF’s motion, it appears that one purchase order (70176124) was partially shipped to VMI (Doc. No. 5 ¶¶ 41–44 (detailing the shipped parts of the order)) and partially withheld. (Doc. No. 26, at 1 (listing purchase order 70176124 as one of the three purchase orders for which it withheld shipment).) All other purchase orders appear to have been shipped or withheld in full. For the rest of the memorandum opinion and order, when the Court refers to the shipped portion of purchase order 70176124, it will specifically note it. The other, general, references to purchase order 70176124 refer solely to the withheld portion. Corp. v. Twombly, 550 U.S. 544, 555, 127 S. Ct. 1955, 167 L. Ed. 2d 929 (2007), and then Ashcroft v. Iqbal, 556 U.S. 662, 678, 129 S. Ct. 1937, 173 L. Ed. 2d 868 (2009)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S.

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Bluebook (online)
AMF Bruns America, L.P. v. Vantage Mobility International, L.L.C., Counsel Stack Legal Research, https://law.counselstack.com/opinion/amf-bruns-america-lp-v-vantage-mobility-international-llc-ohnd-2024.