Commonwealth v. Selective Insurance

68 Va. Cir. 451, 2005 Va. Cir. LEXIS 225
CourtLoudoun County Circuit Court
DecidedSeptember 12, 2005
DocketCase No. (Law) 31935
StatusPublished

This text of 68 Va. Cir. 451 (Commonwealth v. Selective Insurance) is published on Counsel Stack Legal Research, covering Loudoun County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Selective Insurance, 68 Va. Cir. 451, 2005 Va. Cir. LEXIS 225 (Va. Super. Ct. 2005).

Opinion

By Judge James H. Chamblin

This case came before the Court on August 11, 2005, for trial without a jury. In this suit concerning a road construction project in Loudoun County, the Plaintiff, Commonwealth of Virginia, Department of Transportation, (“VDOT”) seeks to recover on a performance bond on the project provided by the Defendant, Selective Insurance Company of America (“Selective”).

After consideration of the evidence and the argument of counsel, judgment is awarded to VDOT against Selective in the amount of $56,954.50 with interest from the date of judgment.

Facts

On or about August 25, 2000, the Virginia Department of Transportation entered into a contract (Plaintiffs Exhibit 1) with New Construction, Inc. (“NCI”) to perform work on a road project on Route 28 in Loudoun County with a total contract value of $1,105,200.80.

Selective Insurance Company of Virginia issued a performance bond (Plaintiffs Exhibit 2) on the Project dated August 7, 2000, in the amount [452]*452of $1,105,200.80. NCI performed the work on the Project under the Contract. Final acceptance of the work, as the term is defined in the Contract, occurred on or about December 3, 2001.

The Contract required the Project to be constructed in accordance with the Virginia Department of Transportation Metric Road and Bridge Specifications, dated January 1997. See Plaintiffs Exhibit 3. Under the Specifications, partial payments were to be made monthly to NCI on the basis of estimates of the quantities and value of the work performed. Such partial estimated payments were made. After the work was completed and accepted, VDOT rendered a final estimate, which determined that NCI owed liquidated damages of $79,800.00 and had been overpaid by $56,954.50.

NCI was given notice of the final estimate and advised that it had a sixty-day period in which to file a claim under Va. Code § 33.1-386. NCI filed a claim asserting that it did not owe the liquidated damages. NCI made no claim as to the over payment. During this administrative process, but before NCI could appear as it had requested before the Commonwealth Transportation Commissioner, VDOT and NCI reached a settlement.

The settlement is embodied in the Release of All Claims (Plaintiffs Exhibit 5) executed by NCI on February 4, 2003. Under the Release, NCI agreed to pay VDOT the sum of $56,954.50 (the overpayment) on or before April 1, 2003, in consideration of elimination of $79,800.00 in liquidated damages.

As required by Va. Code § 33.1-386 and § 2.2-514, the settlement must be approved by the Governor.

NCI did not pay on April 1, 2003.

On August 25, 2003, Governor Warner approved the settlement. Plaintiffs Exhibit 6.

On February 17, 2004, NCI filed a petition in bankruptcy in the United States District Court, Bankruptcy Division, for the Eastern District of Virginia. The bankruptcy proceeding is still pending.

VDOT first notified Selective of the overpayment and settlement on March 9, 2004. Plaintiffs Exhibit 7. VDOT demanded payment of the sum of $56,954.50 under the Performance Bond. Selective refused to pay.

VDOT filed its motion for judgment in the Circuit Court of the City of Richmond on April 28, 2004. The case was transferred to this Court by order entered June 21, 2004.

[453]*453 Legal Analysis

The Performance Bond executed by NCI and Selective specifically refers to the Contract in the following words: “the terms and conditions of said contract and his (NCI) obligations thereunder, including the Specifications, with amendments thereto . . . and such alterations as may be made in said plans and specifications as therein provided for....”

Clearly, the Specifications are covered by the Performance Bond. The Specifications contain the provisions relating to estimated partial payments and a possible overpayment. The Specifications clearly impose an obligation on NCI to repay any finally determined overpayment.

The overpayment requirements, if they come into play, are a part of the contractual obligations imposed on NCI by the Contract and the Specifications. Repayment of any overpayment is just as much a contractual obligation of NCI under the Contract and the Specifications as is the performance of the road work. The Performance Bond references the Contract and the Specifications. Therefore, any required repayment of an overpayment is covered by the Performance Bond. I do not agree with Selective’s argument that the Performance Bond only covers the road work to be performed under the Contract.

There is no doubt that NCI considers itself to be contractually obligated to repay the overpayment. It is merely seeking to discharge the obligation in bankruptcy. If NCI is obligated under the Contract and the Specifications to repay the overpayment, then Selective, as surety, is also liable unless something has occurred that results in a discharge.

Selective seems to argue that VDOT is attempting to collect under the Settlement Agreement, more specifically, the Release. I do not think so. I construe the motion for judgment and the argument of VDOT’s counsel at trial to be that it is suing under the Contract and the Specifications. VDOT is not suing to collect under the settlement agreement or the Release. The Release merely releases VDOT for any claims that NCI may have against VDOT arising out of the project. The Release specifically recites that it is in consideration of the elimination of VDOT’s liquidated damages claim of $79,800.00 resulting in a payment due of the outstanding balance owed by NCI to VDOT in the amount of $56,954.50. The Release does not refer to the $56,954.50 as a payment for a release; it refers to a balance already owed by NCI to VDOT. The Release acknowledges what NCI already owed to VDOT on account of the overpayment. I do not construe it as a settlement of the overpayment [454]*454claim. If anything, it is a settlement of the liquidated damage claim in a way favorable to NCI, and Selective cannot complain about that.

A surety may be discharged if there is a change in the obligation underlying the bond. An accommodation surety is discharged by any change in the obligation. However, a compensated surety must show a material alteration before it is discharged. Board of Supervisors v. Southern Cross Coal, 238 Va. 91, 94 (1989); Southwood Builders, Inc. v. Peerless Ins., 235 Va. 164, 168-69 (1988). Selective, a compensated surety, argues that it is discharged because VDOT caused a material alteration in the underlying obligation.

Before considering whether Selective has been discharged, I must consider the argument of VDOT that the equitable doctrine of discharge cannot be used against the Commonwealth under the principle of sovereign immunity.

VDOT offers no authority that the discharge doctrine is not applicable to the Commonwealth. The Commonwealth cannot use sovereign immunity as a defense in an action based upon a valid contract entered into by a duly authorized agent of the Commonwealth. Wiecking v. Allied Medical Supply Corp., 239 Va. 548, 551 (1990). The reasons for denying immunity are listed in Wiecking as follows:

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Related

Board of Supervisors v. Southern Cross Coal Corp.
380 S.E.2d 636 (Supreme Court of Virginia, 1989)
Wiecking v. Allied Medical Supply Corp.
391 S.E.2d 258 (Supreme Court of Virginia, 1990)
Southwood Builders, Inc. v. Peerless Insurance
366 S.E.2d 104 (Supreme Court of Virginia, 1988)
Phoenix Insurance Company v. Lester Brothers, Inc.
127 S.E.2d 432 (Supreme Court of Virginia, 1962)

Cite This Page — Counsel Stack

Bluebook (online)
68 Va. Cir. 451, 2005 Va. Cir. LEXIS 225, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-selective-insurance-vaccloudoun-2005.