Crescent Univ. City Venture, LLC v. Trussway Mfg., Inc.

CourtSupreme Court of North Carolina
DecidedDecember 18, 2020
Docket407A19
StatusPublished

This text of Crescent Univ. City Venture, LLC v. Trussway Mfg., Inc. (Crescent Univ. City Venture, LLC v. Trussway Mfg., Inc.) is published on Counsel Stack Legal Research, covering Supreme Court of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Crescent Univ. City Venture, LLC v. Trussway Mfg., Inc., (N.C. 2020).

Opinion

IN THE SUPREME COURT OF NORTH CAROLINA

No. 407A19

Filed 18 December 2020

CRESCENT UNIVERSITY CITY VENTURE, LLC

v.

TRUSSWAY MANUFACTURING, INC. and TRUSSWAY MANUFACTURING, LLC

Appeal pursuant to N.C.G.S. § 7A-27(a)(2) from an order and opinion granting

summary judgment in favor of defendants entered on 14 August 2019 by Judge Louis

A. Bledsoe III, Chief Business Court Judge, in Superior Court, Mecklenburg County,

after the case was designated a mandatory complex business case by the Chief Justice

pursuant to N.C.G.S. § 7A-45.4(a). Heard in the Supreme Court on 16 June 2020.

Kiran H. Mehta and William J. Farley III for plaintiff-appellant.

Fox Rothschild LLP, by Elizabeth Brooks Scherer and Jeffrey P. MacHarg; and Martyn B. Hill and Michael A. Harris for defendant-appellees.

MORGAN, Justice.

In this case we must determine whether, under North Carolina law, a

commercial property owner who contracts for the construction of a building, and

thereby possesses a bargained-for means of recovery against a general contractor,

may nevertheless seek to recover in tort for its economic loss from a subcontracted

manufacturer of building materials with whom the property owner does not have

contractual privity. The Business Court determined that North Carolina’s economic CRESCENT UNIV. CITY VENTURE, LLC V. TRUSSWAY MFG., INC.

Opinion of the Court

loss rule requires negligence claims to be based upon the violation of an extra-

contractual duty imposed by operation of law, simultaneously recognizing that

parties generally do not owe each other a duty of care to prevent economic loss. We

agree with the Business Court and therefore affirm the Business Court’s order

granting summary judgment in favor of defendants.

Factual and Procedural Background

Plaintiff Crescent University City Venture, LLC (Crescent) was the owner and

developer of an initiative to build and lease several student apartment buildings near

the campus of the University of North Carolina at Charlotte (the project). In 2012,

Crescent entered into a contract with AP Atlantic, Inc. d/b/a Adolfson & Peterson

Construction (AP Atlantic), a general contractor, whereby AP Atlantic agreed to

construct a multi-building apartment complex on Crescent’s property. As a matter of

course, AP Atlantic entered into agreements with several subcontractors to facilitate

the construction of the project, including a subcontract with Madison Construction

Group, Inc. (Madison) for the provision and installation of wood framing for the

buildings. The AP Atlantic-Madison subcontract required Madison to procure the

floor and roof trusses at issue in the present controversy. The trusses in this context

were structures of wood members held together by metal plates bristling with teeth,

which were pressed into the pieces of wood at points where they connected at angles,

creating a cross-supporting web of triangles. The trusses were delivered

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premanufactured to the project site and were each installed as a single piece to make

up the floor and roof portions of each apartment building. In order to procure trusses

for the project, Madison executed a signed purchase order with Trussway

Manufacturing, Inc. (Trussway). The purchase order included the specifications of

the trusses required by the project and set forth further terms applicable to the sale

of the trusses including an express warranty.

Students of the University of North Carolina at Charlotte began occupying the

apartments for the 2014–2015 academic year. Following a party attended by 80–100

people hosted in one of the units of Building C—one of the student apartment

buildings erected during the project—on 30 January 2015, the occupants of the unit

below reported that their living room ceiling had cracked and was sagging. Crescent

relocated the residents of both units in Building C, after which the residents of a unit

in Building E reported similar problems on 1 May 2015. Initial inspections revealed

that the floor trusses between the apartments in Buildings C and E were defective.

Crescent hired an engineering firm, Simpson Gumpertz & Heger, Inc. (SGH), to

conduct an investigation into both the identified failures as well as a random

sampling of the remaining apartments to determine if the structural defects were

isolated or systemic. After examining the apartments with noticeable defects and a

wider sample of other apartments, SGH informed Crescent that it believed the floor-

truss defects were systemic and pervasive throughout the project. The investigation

-3- CRESCENT UNIV. CITY VENTURE, LLC V. TRUSSWAY MFG., INC.

revealed that 13.6% of the metal plates connecting the wood members of each truss

that SGH inspected had failed or presented an unsafe defect, and reports produced

by SGH detailed the repairs necessary to bring the project back to an acceptable

standard. While having initially consulted AP Atlantic to conduct the necessary

repairs, the parties to this action disagreed about the reasonableness of the proposed

timeframe and repair plan Crescent developed with SGH. Crescent instead enlisted

the assistance of a third party, Summit Contracting Group, Inc. to complete the

planned repairs.

On 5 August 2015, AP Atlantic filed suit against Crescent for outstanding

payments on the project, to which Crescent responded with a breach of contract

counterclaim on multiple grounds including the defective trusses. Crescent initiated

a separate action against AP Atlantic’s parent company to enforce a performance

guaranty while AP Atlantic maintained multiple derivative claims against the

subcontractors on the project, including Trussway. The matter was designated as a

complex business case and assigned to the North Carolina Business Court for

administration and resolution. The Business Court consolidated the actions on 10

October 2016. Following multiple rounds of pleadings, a lengthy discovery process,

and several settlement agreements and voluntary dismissals, the resulting

procedural posture led Crescent to move the Business Court to realign the parties,

with Crescent as plaintiff, AP Atlantic and its parent company as defendants, and

-4- CRESCENT UNIV. CITY VENTURE, LLC V. TRUSSWAY MFG., INC.

the subcontractors as third-party and fourth-party defendants. All parties to the

consolidated proceedings agreed, and the Business Court granted Crescent’s motion

on 11 December 2017.

On 12 February 2018, the parties to the consolidated action filed motions for

summary judgment, while Crescent filed a complaint asserting a single negligence

claim against Trussway, along with a motion to consolidate the new claim with the

ongoing matters. Crescent’s new complaint alleged that Trussway’s negligence in

manufacturing the trusses resulted in almost eight million dollars in damages from

a combination of the project-wide repairs and stipends to residents for temporary

accommodations, transportation, and storage. After this new action was itself

designated as a complex business case on 7 March 2018, Trussway filed a motion to

dismiss Crescent’s new negligence complaint, arguing that the “prior action pending”

doctrine barred such a claim. The Business Court held a hearing on the summary

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