Bay Point Condominium Ass'n Board of Directors v. Mid-Atlantic Insurance

54 Va. Cir. 124, 2000 Va. Cir. LEXIS 555
CourtNorfolk County Circuit Court
DecidedSeptember 20, 2000
DocketCase No. (Law) L00-948
StatusPublished
Cited by1 cases

This text of 54 Va. Cir. 124 (Bay Point Condominium Ass'n Board of Directors v. Mid-Atlantic Insurance) is published on Counsel Stack Legal Research, covering Norfolk County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bay Point Condominium Ass'n Board of Directors v. Mid-Atlantic Insurance, 54 Va. Cir. 124, 2000 Va. Cir. LEXIS 555 (Va. Super. Ct. 2000).

Opinion

By Judge Joseph A. leafe

This matter comes before the Court on Defendant Mid-Atlantic Insurance Corporation’s demurrers to certain counts of Plaintiff s Motion for Judgment. Plaintiffs originally filed suit against the Defendant Mid-Atlantic, doing business as HW10, as the Warranty Company of RML, on April 28,2000, to recover for structural defects in the condominium units and common areas of the Bay Point complex.

RML was the general contractor who constructed the units in question. Mid-Atlantic contracted with RML (“Builder Agreement”) to provide insurance in the event that there were defects in the construction of the units. In the builder agreement, RML agreed to enroll each unit that was constructed in HWlO’s program and HW10 would then issue a Home Protection policy to the homeowner upon occupancy. RML also agreed to be responsible for certain defects (hat are spelled out in the agreement. The homeowner was to make its complaint to HW10 who would then inform the builder of the problem but if the builder failed to respond, HW10 agreed to resolve the homeowner’s complaint itself. Mid-Atlantic did in fact issue a Home Protection Policy (“Policy”) to each condominium unit owner upon closing.

The Home Protection Policy is a separate document that lists the responsibilities of HW10 to each individual homeowner with regard to certain defects including major structural defects as defined in the policy. The individual unit owners began experiencing trouble and informed HW10 of the [125]*125problem, but they neglected to do anything about it. Plaintiffs are the Board of Directors, the Bay Point Condominium Association, and sixty individual unit owners who filed a Motion for Judgment on four different counts: (1) breach of contract by Mid-Atlantic; (2) third-party beneficiaries (plaintiffs as individual owners) of the contract between RML and Mid-Atlantic; (3) third-party beneficiary (plaintiff Bay Point Condominium Association) of the contract between the individual unit owners and Mid-Atlantic; and (4) Breach of Warranty by Mid-Atlantic. Mid-Atlantic/HW10 filed demurrers as to Counts n, III, and IV.

A demurrer tests the sufficiency of the factual allegations to determine whether the motion for judgment states a cause of action. Fun v. Virginia Military Inst., 245 Va. 249, 252, 427 S.E.2d 181, 183 (1993). When ruling on a demurrer the Court must not evaluate or decide the actual merits of a claim. Id. According to the Rules of the Supreme Court, die pleading “shall state the facts on which the party relies in numbered paragraphs, and it shall be sufficient if it clearly informs the opposite party of the true nature of the claim or defense.” Rule 1:4(d); see also Miller v. Grier S. Johnson, Inc., 191 Va. 768, 776, 62 S.E.2d 870, 874 (1951). The Virginia Supreme Court has stated that trial courts should not incorrectly short-circuit litigation at the pretrial stage by deciding the dispute without permitting the parties to have a trial on the merits. CaterCorp, Inc. v. Catering Concepts, Inc., 246 Va. 22, 431 S.E.2d 277 (1993). Further, in deciding whether to grant the demurrers, the Court must accept as true all facts and reasonable inferences drawn from the Motion for Judgment. See Fox v. Custis, 236 Va. 69, 372 S.E.2d 373 (1988).

Pursuant to Virginia Code § 55-22, a person who is not a party to a contract may maintain an action even though they are not named in the contract itself, if they show that the parties to the contract clearly and definitely intended to confer a benefit directly upon that person. See Virginia Code § 55-22; Levine v. Selective Ins. Co. of America, 250 Va. 282, 462 S.E.2d 81 (1995). Thus, this Code section “has no application unless the party against whom liability is asserted has assumed an obligation for the benefit of a third party.” Cobert v. Home Owners Warranty Corp., 239 Va. 460, 391 S.E.2d 263 (1990), quoting Copenhaver v. Rogers, 238 Va. 361, 367, 384 S.E.2d 593, 596 (1989). The statute does not purport to create a contract where none exists. Burton v. Chesapeake Box, etc., 190 Va. 755, 767, 57 S.E.2d 904 (1950).

One who is a mere incidental beneficiary cannot sue thereon. Cobert, supra. The Virginia Supreme Court has expressly recognized that “under traditional rules, it will no doubt be difficult for a litigant... to meet the requirements of third-party beneficiary claims.” Copenhaver, supra at 371. [126]*126The essence of a third-party beneficiary’s claim is that others have agreed between themselves to bestow some benefit upon the third party and one of the parties to the agreement has failed to meet his end of the bargain. Id.; Allen v. Lindstrom, 237 Va. 489, 379 S.E.2d 450 (1989); Valley Landscape Co. v. Rolland, 218 Va. 257, 237 S.E.2d 120 (1977). A third person cannot maintain an action merely because that person would receive some benefit from its performance or because they are injured by a breach of the contract. Id. 262, quoting Engle Acoustic & Tile, Inc. v. Grenfell, 223 So. 2d 613, 620 (Miss. 1969) (holding that a subcontractor had no claim against an architect on a construction contract between the architect and owner). The provision sought to be invoked “must have been inserted in the contract directly or primarily for his benefit____” Id. The four comers of the contract evidence whether the contracting parties clearly and definitely intended to benefit a third-party directly. Radosevic v. Virginia Intermont College, 651 F. Supp. 1037 (W.D. Va. 1987). See also Wedgewood Homes, Inc. v. Southern Title Ins. Corp., 24 Va. Cir. 262 (Fredericksburg 1991) (granting demurrer and distinguishing Cobert from the case at issue because in Cobert the policy expressly stated that a “purchaser” was a beneficiary and the policy at issue contained no such language).

As to Counts II and IQ dealing with plaintiffs third-party beneficiary claims, Defendant argues that Plaintiffs fail to state a claim because there was no intent on the part of the contracting parties to confer a benefit on them with respect to both the contract between RML and Mid-Atlantic/HW10 (Count Q) and the contract between the individual unit owners and Mid-Atlantic (Count IQ). Defendant asserts that this is especially true since each individual homeowner was issued their own insurance policy at the time of closing.

Plaintiffs contend that they are third-party beneficiaries and rely on Cobert in making these claims. In Cobert

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54 Va. Cir. 124, 2000 Va. Cir. LEXIS 555, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bay-point-condominium-assn-board-of-directors-v-mid-atlantic-insurance-vaccnorfolk-2000.