Bpg Inspection, LLC v. Jessique Omstead

CourtCourt of Appeals of Georgia
DecidedJanuary 31, 2023
DocketA22A1730
StatusPublished

This text of Bpg Inspection, LLC v. Jessique Omstead (Bpg Inspection, LLC v. Jessique Omstead) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bpg Inspection, LLC v. Jessique Omstead, (Ga. Ct. App. 2023).

Opinion

FIFTH DIVISION MCFADDEN, P. J., BARNES, P. J., and LAND, J.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

January 31, 2023

In the Court of Appeals of Georgia A22A1730. BPG INSPECTION, LLC et al. v. OMSTEAD.

LAND, Judge.

This is an appeal from a grant of partial summary judgment to plaintiff Jessique

Omstead in her wrongful death action against BPG Inspection, LLC and James

Golden. Plaintiff’s husband engaged BPG to inspect a home that he and plaintiff

subsequently purchased. Golden was the home inspector for BPG who inspected the

home in February 2020 and returned for a follow-up inspection in March 2020. More

than a year after this inspection occurred, a retaining wall between the house and the

driveway collapsed onto Mr. Omstead, resulting in his tragic and untimely death.

Plaintiff sued BPG and Golden for wrongful death, asserting claims sounding in tort

and contract. The BPG inspection contract that plaintiff’s husband signed contained several

provisions seeking to limit the liability of BPG and its employees, including a one-

year limitation period for the filing of lawsuits (whether those lawsuits asserted

claims sounding in tort, contract, or otherwise) and a contractual cap on damages. The

parties moved for summary judgment with respect to the applicability and

enforceability of these provisions. The trial court granted plaintiff’s motion and

denied defendants’ motion, ruling that these provisions did not apply to plaintiff’s

claims, and to the extent they did, were void as against public policy. Defendants

appeal, arguing that the contract’s one-year limitation period and its cap on damages

apply to this case and should be enforced. We agree with the defendants with respect

to the one-year limitation period and therefore reverse. Because this ruling is

dispositive of the case, we need not address the defendants’ other arguments.

“The interpretation of a contract is normally a question of law to be resolved

by the court, and the orders of the lower court in this case are therefore subject to de

novo review.” (Citation and punctuation omitted.) Sherwood v. Williams, 347 Ga.

App. 400, 405 (2) (820 SE2d 141) (2018). So viewed, the record shows that on

February 13, 2020, Mr. Omstead signed an agreement engaging BPG to inspect a

house that he and Mrs. Omstead were considering purchasing in exchange for an

2 inspection fee of $380. The agreement provided in relevant part that the inspection

would be “an impartial, noninvasive, visual examination of specific systems,

structures, and components of buildings located on the subject property, as they exist

at the time of the inspection” and further specified that the “inspection will be limited

to those specific installed systems, structures and components that are readily

accessible and visually observable.” The agreement specified that the inspection

would not include “engineering inspections and/or code compliance inspections” and

that the inspector would not “speculate regarding the presence or absence of

concealed conditions, latent defects or the future performance” of the house and its

systems and structures.

In a section headed “LIMITATIONS ON LIABILITY,” the agreement sought

to limit the defendants’ liability in several respects, including the following:

IF YOU DISCOVER A DEFECT FOR WHICH WE MAY BE LIABLE TO YOU, YOU MUST PROMPTLY NOTIFY US, BUT IN ALL CASES WITHIN 14 DAYS OF DISCOVERY, AND GIVE US A REASONABLE OPPORTUNITY TO RE-INSPECT THE PROPERTY BEFORE YOU REPAIR OR REPLACE THE DEFECT. . . .

BPG’S LIABILITY TO YOU FOR CLAIMS ARISING FROM OR RELATED IN ANY WAY TO OUR INSPECTION OR OUR

3 REPORT, INCLUDING, WITHOUT LIMITATION, ERRORS AND OMISSIONS . . . WILL NOT BE MORE THAN THE LESSER OF ACTUAL DAMAGES OR TEN TIMES (10X) THE INSPECTION FEE. . . .

YOU MAY NOT FILE A LEGAL ACTION, WHETHER SOUNDING IN TORT (EVEN IF DUE TO OUR NEGLIGENCE OR OTHER FAULT), CONTRACT, ARBITRATION OR OTHERWISE, AGAINST US OR OUR EMPLOYEES MORE THAN ONE YEAR AFTER THE INSPECTION, EVEN IF YOU DO NOT DISCOVER A DEFECT UNTIL AFTER THAT. THIS TIME LIMIT MAY BE SHORTER THAN THE LAW OTHERWISE PROVIDES.

(Capitalization and bold in original; italics supplied.) By signing the agreement, Mr.

Omstead acknowledged that he “ha[d] carefully read the entirety of this Agreement

including any limitations of liability and agree[d] to the terms herein.”

On the same day that Mr. Omstead signed the agreement, BPG’s employee

James Golden performed the inspection. Golden is not an engineer and did not hold

himself out as one. The report he prepared and gave to the Omsteads included the

following:

[H]ome inspections include a visual examination of readily accessible systems and components to help identify material defects as they exist

4 at the time of the inspection. . . . Latent, inaccessible, or concealed defects are excluded from this inspection.

(Underline in original). Among the structures Golden inspected was a retaining wall

that ran the length of the house’s driveway. The wall stood approximately seven feet

tall at its highest point, was constructed of concrete blocks, and did not have any

drainage holes. The report noted that the wall had been “[i]nspected,” which the

report defined as “visually observed and appear[ing] to be functioning as intended.”

On March 7, 2020, Golden returned to the property to reinspect several items that Mr.

Omstead had asked the sellers to repair. The retaining wall was not one of these

items.

After receiving the inspection reports, the Omsteads purchased the property.

On July 16, 2020, having discovered that water was leaking into the garage through

the drywall running parallel to the retaining wall, plaintiff posted on Instagram that

“there are cracks in the retaining wall that spit water when it rains, but no official

drain holes.” The Omsteads did not notify BPG of these observations.

On July 19, 2021, more than a year after the completion of the home inspection,

the Omsteads placed a plastic tarp and a piece of particle board on top of the retaining

wall during a rainstorm to divert water away from the garage. As plaintiff stood on

5 the embankment behind the wall and Mr. Omstead stood on the driveway near the

garage, the wall collapsed onto Mr. Omstead. He died shortly afterward as a result of

blunt force trauma to his torso and lacerations to his liver. The collapse of the wall

revealed that a wooden crosstie wall had been left in place behind the wall, that the

cells of the concrete blocks were unfilled and lacked rebar, and that no gravel had

been used in the construction of the wall.

In September 2021, after giving notice to BPG of the collapse, plaintiff filed

this wrongful death action alleging negligence, fraud, breach of contract, and breach

of warranty against BPG and Golden.1 The defendants moved for summary judgment

to enforce the agreement’s one-year limitation provision and its cap on damages.

Plaintiff filed a cross-motion asking that the trial court declare these provisions of the

agreement inapplicable to this case and void as against public policy. After a hearing,

the trial court denied defendants’ motion and granted plaintiff’s motion based on its

conclusion that neither of the provisions applied to this case, and to the extent they

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