Burns Electrical Services v. Patel, S.

CourtSuperior Court of Pennsylvania
DecidedAugust 6, 2024
Docket2687 EDA 2023
StatusUnpublished

This text of Burns Electrical Services v. Patel, S. (Burns Electrical Services v. Patel, S.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Burns Electrical Services v. Patel, S., (Pa. Ct. App. 2024).

Opinion

J-S17035-24

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

BURNS ELECTRICAL SERVICES, INC. : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : SHAILESH PATEL AND SHREE : MOHAN, LLC : : No. 2687 EDA 2023 Appellants :

Appeal from the Order Entered September 20, 2023 In the Court of Common Pleas of Montgomery County Civil Division at No(s): 2020-15993

BEFORE: BOWES, J., KING, J., and BENDER, P.J.E.

MEMORANDUM BY BENDER, P.J.E.: FILED AUGUST 6, 2024

Appellants, Shailesh Patel and Shree Mohan, LLC, appeal from the trial

court’s September 20, 2023 order, which granted summary judgment in favor

of Appellee, Burns Electrical Services, Inc. (“Burns”); awarded $43,823.20 to

Burns; and dismissed with prejudice Appellants’ counterclaims. After review,

we reverse and remand.

This case was initiated in the court of common pleas as an appeal from

a district justice judgment. Burns had sued Appellants in magisterial district

court and obtained a judgment against Appellants in the amount of

$12,219.25.

Following Appellants’ appeal to the court of common pleas, Burns filed

a complaint in October of 2020. Therein, inter alia, Burns alleged that, in

2017, Appellant Patel contracted with Burns within the meaning of the J-S17035-24

Contractor and Subcontractor Payment Act (“CASPA”), 73 P.S. §§ 501-517.

Burns’s Complaint, 10/27/20, at 2 ¶ 10.1 According to Burns, at the request

of Appellant Patel, Burns purchased materials and performed electrical work

on an ice cream kiosk in Willow Grove Park Mall which it believed Appellant

Shree Mohan, LLC owned and operated. Id. at 2 ¶ 11. Burns claimed that

the work was completed before August 9, 2017, the date when — at Burns’s

direction — the electrical work was inspected and approved by United

Inspection Agency, Inc. Id. at 2 ¶ 12. After the final inspection approval,

Burns said it submitted a final invoice for payment, with a balance due of

$17,465.27, on August 10, 2017. Id. at 2 ¶ 14.2 Burns averred that Appellant

Patel made one payment of $5,000.00 to Burns, and failed to provide any

written notice of a deficiency in the work, as required under CASPA. Id. at 2

____________________________________________

1 This Court has explained that:

CASPA is a comprehensive statute enacted in 1994 to cure abuses within the building industry involving payments due from owners to contractors, contractors to subcontractors, and subcontractors to other subcontractors. The underlying purpose of CASPA is to protect contractors and subcontractors and to encourage fair dealing among parties to a construction contract. The statute provides rules and deadlines to ensure prompt payments, to discourage unreasonable withholding of payments, and to address the matter of progress payments and retainages. Under circumstances prescribed in the statute, interest, penalties, attorney’s fees, and litigation expenses may be imposed on an owner, contractor, or subcontractor who fails to make payment to a contractor or subcontractor in compliance with the statute.

El-Gharbaoui v. Ajayi, 260 A.3d 944, 954 (Pa. Super. 2021) (cleaned up).

2 Burns attached no exhibits to its complaint, including this invoice.

-2- J-S17035-24

¶¶ 15, 16 (referencing 73 P.S. § 506(b)(1)). 3 Burns contended that Appellants

owe Burns the balance of the invoice — $12,465.27 — as well as interest,

penalties, reasonable attorneys’ fees, and court costs. Id. at 3 ¶¶ 18-23.

In November of 2020, Appellants filed an answer to Burns’s complaint,

along with affirmative defenses and counterclaims. 4 Therein, in pertinent

part, Appellants acknowledged that Burns provided paperwork showing that

an inspection was performed by United Inspection Agency, Inc., but stated

that the inspection was conducted and approved on August 8, 2017, not

August 9, 2017. Appellants’ Answer, Affirmative Defenses, and

Counterclaims, 11/17/20, at 3 ¶ 12. Further, they denied that Burns

completed the electrical work and claimed that they “were forced to employ

another electrician to complete the outstanding tasks required to obtain the

3 As discussed infra, if an owner withholds payment from a contractor for a

deficiency item, “the amount withheld shall be reasonable and the owner shall notify the contractor of the deficiency item by a written explanation of its good faith reason within 14 calendar days of the date that the invoice is received.” 73 P.S. § 506(b)(1). Failure to do so constitutes a waiver of the basis to withhold payment and necessitates payment of the contractor in full for the invoice. 73 P.S. § 506(b)(2).

4 Though not mentioned by either party, it appears that this filing did not include a notice to plead. See Pa.R.Civ.P. 1026(a) (“[E]very pleading subsequent to the complaint shall be filed within twenty days after service of the preceding pleading, but no pleading need be filed unless the preceding pleading contains a notice to defend or is endorsed with a notice to plead.”); Note to Pa.R.Civ.P. 1361 (“A responsive pleading is not required to be filed unless a notice to plead has been endorsed on the prior pleading other than a complaint.”).

-3- J-S17035-24

inspection and approval.” Id.5 Appellants also denied Burns’s allegation that

Burns submitted a final invoice for payment with a balance due of $17,465.27

on August 10, 2017, claiming that the document referenced speaks for itself.

Id. at 3-4 ¶ 14.6 By way of further response, Appellants explained that, “when

the electrical work was approved on August 8, 2017, [Appellants] paid [Burns]

on that same day with a check [in] the amount of $5,000.00 for the full,

verbally agreed[-]upon amount due to [Burns] for the approved electrical

work.” Id. They added that Burns’s invoice was sent to Appellants sometime

between August 10, 2017 and August 25, 2017, which was after Burns had

already accepted and cashed Appellants’ check in the amount of $5,000.00.

Id. As for Burns’s claim that Appellants did not provide it with written notice

of a deficiency in the work as required under CASPA, Appellants denied that

allegation on the basis that it states a legal conclusion to which no responsive

pleading is required. Id. at 4 ¶ 16. Appellants also denied that they owed

Burns the invoice’s balance of $12,465.27, asserting that they “had an oral

agreement that the electrical work to be performed in accordance with the

specifications provided to [Burns] by the kiosk’s designer … would cost

$5,000.00.” Id. at 4 ¶ 18. ____________________________________________

5 It is not clear to us when Appellants employed the other electrician to obtain

the inspection and approval. Moreover, as set forth infra, although Appellants stated in this filing that they were forced to employ another electrician to receive the approval, Appellants represent in subsequent filings that Burns’s work was sufficient to obtain the approval.

6 Although Appellants attached other exhibits to this filing, Appellants did not

attach Burns’s invoice.

-4- J-S17035-24

In addition, Appellants’ counterclaims against Burns and its owner

alleged breach of contract, fraud, fraudulent misrepresentation, and negligent

misrepresentation. The counterclaims centered around Appellants’ assertions

that it was represented to them that Burns would be able to complete the

work for $5,000.00 or less, that Burns had the requisite knowledge and

experience to perform the required electrical work, and that the electrical work

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Cite This Page — Counsel Stack

Bluebook (online)
Burns Electrical Services v. Patel, S., Counsel Stack Legal Research, https://law.counselstack.com/opinion/burns-electrical-services-v-patel-s-pasuperct-2024.