Consol. Distribution Corp. v. McLawhorn

CourtCourt of Appeals of North Carolina
DecidedSeptember 3, 2025
Docket24-658
StatusUnpublished

This text of Consol. Distribution Corp. v. McLawhorn (Consol. Distribution Corp. v. McLawhorn) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Consol. Distribution Corp. v. McLawhorn, (N.C. Ct. App. 2025).

Opinion

An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority. Citation is disfavored, but may be permitted in accordance with the provisions of Rule 30(e)(3) of the North Carolina Rules of Appellate Procedure.

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA24-658

Filed 3 September 2025

Wake County, No. 21 CVD 010791-910

CONSOLIDATED DISTRIBUTION CORP., Plaintiff,

v.

ABEL McLAWHORN and SARAH WECHSBERG, Defendants.

Appeal by Defendants from judgment entered 31 October 2023 by Judge Ned

W. Mangum in Wake County District Court. Heard in the Court of Appeals 23 April

2025.

Law Office of Matthew I. Van Horn, PLLC, by Matthew I. Van Horn, for Plaintiff–Appellee.

The Armstrong Law Firm, PA, by L. Lamar Armstrong III, for Defendants– Appellants.

MURRY, Judge.

Abel J. McLawhorn and Sarah S. Wechsberg (Defendants) appeal from the

District Court’s (trial court) judgment (1) joining Wechsberg as a co-defendant to the

case, (2) finding for Consolidated Distribution Corporation (Plaintiff) that Defendants

materially breached the parties’ contract, and (3) awarding Plaintiff attorney’s fees

and costs. Plaintiff also requests sanctions against Defendants for raising this appeal. CONSOL. DISTRIB. CORP. V. MCLAWHORN

Opinion of the Court

For the reasons below, this Court (1) affirms the trial court’s exercise of jurisdiction

over Wechsberg, (2) affirms the trial court’s conclusion regarding material breach, (3)

vacates the trial court’s award of attorney’s fees and costs to Plaintiff and remanded

for further findings on its reasonableness, and (4) denies Plaintiff’s request for Rule

34 sanctions.

I. Background

Plaintiff specializes in the “design and overs[ight]” of “custom[-]cabinetry”

installation and typically works with commercial clients. In May 2020, through its

owner, John H. Whitford, Plaintiff contracted with McLawhorn to design and procure

custom cabinets for Wechsberg, McLawhorn’s girlfriend, as a personal favor and

“professional courtesy.” Across a series of emails between the parties, Plaintiff

(through various authorized representatives) agreed to certain contractual terms

undisputed on appeal: (1) that Plaintiff would design and deliver custom cabinets

procured from a third-party vendor (2) for an $85/hour fee and 16.67% gross-margin

markup on raw materials. After the core dispute arose, though, McLawhorn asserted

in a 14 January 2021 text message that the terms also included “cash on delivery”

(COD) of the custom cabinets.

The parties also disputed whether Wechsberg was a party to the agreement.

Defendants did not dispute or object to this estimate at the time. The custom cabinets

were delivered on 9 November 2020, and Plaintiff invoiced McLawhorn three days

later for $14,371.73. McLawhorn did not dispute the price but objected to the

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workmanship of the cabinets shortly after delivery, which Plaintiff sought to address

by sending repairmen to Wechsberg’s home. McLawhorn then delivered two checks

totaling $11,500 to Plaintiff on 19 November 2020. Over 177 days after delivery,

McLawhorn emailed Plaintiff stating that he had withheld the remaining payment

under their agreement due to issues with the craftsmanship of the cabinets upon

installation. Although Plaintiff agreed to fix the issues under warranty upon full

payment or upon placing the remaining balance into an escrow account, Defendants

hired third parties to complete the repairs at cost instead.

In August 2021, Plaintiff sued McLawhorn in small-claims court and won a

judgment against him. Wechsberg was not a party to this initial proceeding.

McLawhorn then appealed to the district court for a trial de novo on 13 August 2021

under N.C.G.S. § 7A-228. N.C.G.S. § 7A-228(a)–(b) (2023). Plaintiff filed its district

court complaint against both McLawhorn and Wechsberg on 31 January 2022.1

Defendants filed an answer denying Plaintiff’s claims in relevant part and asserting

a defense that Plaintiff “failed to state any claim upon which relief can be granted.”

(Citing N.C. R. Civ. P. 12(b)(6).) At a district court trial held on 18 September 2023,

1 Defendants moved on 30 March 2022 to dismiss Plaintiff’s de novo complaint for an alleged failure to join Wechsberg “[ ]as . . . a party . . . in . . . small[-]claims court”; the trial court granted this motion “without prejudice” on 1 July 2022. Two months later, Plaintiff amended its complaint to add Wechsberg as a co-defendant. Because “any claim . . . dismissed without prejudice” “upon order of [a] judge” “may be [re]commenced within one year” so long as the “new action [is] based on the same claim,” these procedural maneuvers do not impact the trial court’s jurisdiction of Wechsberg as analyzed further in Section III.A of this opinion. N.C. R. Civ. P. 41(a)(2).

-3- CONSOL. DISTRIB. CORP. V. MCLAWHORN

Plaintiff testified that the cabinets had not yet been installed when he received

partial payments totaling $11,500 from McLawhorn. McLawhorn testified that he

withheld payment of $2,871.73 because of “design issues in the cabinet[s]” and “three

missed measurements” in the cabinet boxes out of the entire array, “only two” of

which he “discovered within days of delivery.” Subsequently, the trial court entered

a judgment for Plaintiff against Defendants on 30 October 2023. It found that

McLawhorn operated as Wechsberg’s agent during the course of the parties’

agreement. The trial court ordered Defendants to pay Plaintiff $2,600 in damages

plus interest, $9,500 for Plaintiff’s “reasonable attorney’s fees” under N.C.G.S.

§ 6-21.5, and $186 for other costs incurred by Plaintiff under N.C.G.S. § 6-21.1.

Defendants timely appealed the trial court’s ruling on 27 November 2023.

II. Jurisdiction

This Court has jurisdiction to hear Defendant’s appeal of the trial court’s

judgment because it is the “final judgment of a district court in a civil action”

regarding the contractual dispute between the parties. N.C.G.S. § 7A-27(b)(2) (2023).

III. Analysis

Defendants argue on appeal that the trial court erred (1) by entering judgment

against Wechsberg without either personal or subject-matter jurisdiction over her,

(2) by finding that Defendants materially breached the parties’ contract in failing to

pay Plaintiff the full contractual amount, and (3) by awarding attorney’s fees and

costs for Plaintiff against Defendants. Plaintiff also requests appellate sanctions

-4- CONSOL. DISTRIB. CORP. V. MCLAWHORN

against Defendants under N.C. R. App. P. 34(a)(1), (3). We generally review the

appeal of a bench-trial judgment for whether “competent evidence . . . support[s] the

trial court’s findings of fact and whether th[os]e findings support the conclusions of

law and ensuing judgment.” Cartin v. Harrison, 151 N.C. App. 697, 699 (2001)

(quotation omitted). For the reasons below, this Court (1) affirms the trial court’s

exercise of jurisdiction over Wechsberg, (2) affirms the trial court’s conclusion that

Defendants materially breached the contract, (3) vacates the trial court’s award of

attorney’s fees and costs to Plaintiff and remands for further findings on its

reasonableness, and (4) denies Plaintiff’s motion to impose Rule 34 sanctions against

Defendants.

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