Earnhardt Plumbing, LLC v. Thomas Builders, Inc.

CourtCourt of Appeals of North Carolina
DecidedNovember 19, 2025
Docket25-36
StatusPublished

This text of Earnhardt Plumbing, LLC v. Thomas Builders, Inc. (Earnhardt Plumbing, LLC v. Thomas Builders, Inc.) 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
Earnhardt Plumbing, LLC v. Thomas Builders, Inc., (N.C. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA25-36

Filed 19 November 2025

Cumberland County, No. 22CVS001277-250

EARNHARDT PLUMBING, LLC, Plaintiff,

v.

THOMAS BUILDERS, INC. and THOMAS PROPERTIES OF NORTH CAROLINA, LLC, Defendants.

Appeal by Defendants from Order entered 23 July 2024 by Judge Patrick T.

Nadolski in Cumberland County Superior Court. Heard in the Court of Appeals 12

August 2025.

Troy D. Shelton and James R. Vann for Plaintiff-Appellee.

Penn Stuart & Eskridge, P.C., by M. Shaun Lundy, for Defendants-Appellants.

HAMPSON, Judge.

Factual and Procedural Background

Thomas Builders, Inc., and Thomas Properties of North Carolina, LLC,

(collectively, Defendants) appeal from an Order requiring them to arbitrate a breach

of contract claim brought by Earnhardt Plumbing, LLC, in Cumberland County,

North Carolina. The Record before us tends to reflect the following:

Plaintiff entered into a written agreement with Defendants under which

Plaintiff agreed to provide and install a plumbing and gas line system for a hotel EARNHARDT PLUMBING, LLC V. THOMAS BUILDERS, INC.

Opinion of the Court

Defendants were constructing (the Contract). The Contract included an arbitration

clause:

Any claim arising out of or related to this Subcontract, except claims as otherwise provided in Subparagraph 4.1.3, shall be subject to arbitration. Prior to arbitration, the parties shall endeavor to resolve disputes by mediation. Claims not resolved by mediation shall be decided by arbitration. Demand for arbitration shall be filed in writing with the other party. A demand for arbitration shall be made within the time limits specified in the conditions of the Prime Contract as applicable, and in other cases within a reasonable time after the claim has arisen, and in no event shall it be made after the date when institution of legal proceedings based on such a claim would be barred by the applicable statute of limitation. The parties shall select the arbitrator by the same procedures set forth in Paragraph 19a for selection of the mediator; provided, however, that such arbitrator must have experience in the construction industry, either as a contractor, design professional, or attorney, and must have had no prior dealings with either party. The Arbitration shall be held at the discretion of the Contractor either at the Contractor’s principle [sic] place of business or where the project is located.

On 7 March 2022, Plaintiff filed a Complaint alleging Defendants had failed to

pay for the services rendered under the Contract, in the amount of $159,488.50.

Defendants moved to dismiss or stay the proceedings under the Contract’s arbitration

clause. Defendants sought to enforce the arbitration clause and, in particular, require

the arbitration take place in Tennessee, where Thomas Builders, Inc., is registered.

Plaintiff agreed the Contract required the matter be arbitrated but argued the

portion of the provision giving Defendants discretion to choose Tennessee as the

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forum for arbitration was unenforceable.

The trial court denied the motion to dismiss and allowed the motion to stay

proceedings pending arbitration. It held the provision placing the forum in Tennessee

was unenforceable under Section 22B-3 of our General Statutes and that the Federal

Arbitration Act (FAA) did not preempt the application of this provision. Accordingly,

it ordered arbitration be conducted in North Carolina.

Defendants appealed that decision to this Court. Earnhardt Plumbing, LLC v.

Thomas Buiders, Inc., 291 N.C. App 1, 893 S.E.2d 564 (2023). We concluded we could

not determine whether the FAA preempts Section 22B-3 in this case because the trial

court did not make any findings of fact regarding whether the Contract involves

interstate commerce. Id. at 6, 893 S.E.2d at 568. We therefore remanded the case to

the trial court for findings of fact as to whether the Contract evidences a transaction

involving interstate commerce and, based on that fact-finding, to apply the applicable

law to the forum-selection clause contained in the Contract. Id.

On remand, the trial court found the Contract involves interstate commerce

and concluded the FAA preempts Section 22B-3 as applied to the forum-selection

clause. However, it additionally determined the Contract’s forum-selection clause is

permissive, not mandatory, and therefore unenforceable under North Carolina law.

It directed the parties to arbitrate the matter in Cumberland County, North Carolina.

Defendants timely filed notice of appeal.

Appellate Jurisdiction

-3- EARNHARDT PLUMBING, LLC V. THOMAS BUILDERS, INC.

The trial court’s Order allowing Defendant’s Motion to Stay Proceedings is

interlocutory and not final in nature. “An interlocutory order is one made during the

pendency of an action, which does not dispose of the case, but leaves it for further

action by the trial court in order to settle and determine the entire controversy.”

Veazey v. City of Durham, 231 N.C. 357, 362, 57 S.E.2d 377, 381 (1950). “Generally,

a party has no right to appeal an interlocutory order.” Cox v. Dina-A-Mate, Inc., 129

N.C. App. 773, 775, 501 S.E.2d 353, 354 (1998). However, as we previously held in

this case, the trial court’s Order denying Defendants their contractual right to select

the forum for arbitration affects a substantial right. 291 N.C. App. at 4, 893 S.E.2d

at 567. Accordingly, we have jurisdiction to review this matter pursuant to N.C. Gen.

Stat. § 7A-27(b)(3)(a) (2023). Id.

Issue

The sole issue on appeal is whether the trial court erred in holding the forum-

selection clause to be permissive—not mandatory—and unenforceable under North

Carolina law—despite the applicability of the FAA and the language of the clause

itself—and ordering the parties to arbitrate in Cumberland County, North Carolina.

Analysis

Defendants argue the trial court erred in ordering arbitration be held in

Cumberland County because the Contract contains a mandatory forum-selection

-4- EARNHARDT PLUMBING, LLC V. THOMAS BUILDERS, INC.

clause that must be given effect under the Federal Arbitration Act. 1 That clause

provides:

The Arbitration shall be held at the discretion of [Defendants] either at [Defendants’] principle [sic] place of business or where the Project is located.

Defendants argue the FAA preempts North Carolina law, which would render this

clause unenforceable insofar as it provides for arbitration outside of North Carolina.

Plaintiff argues the FAA does not apply because the Contract does not involve

interstate commerce and, even if the FAA applied, it would also require arbitration

be conducted in North Carolina. Plaintiff also argues the trial court did not err in

determining the clause is permissive, rather than mandatory, and therefore

unenforceable.

A. Interstate commerce

As a threshold matter, we must determine if the FAA applies to the Contract.

“The FAA will apply if the contract evidences a transaction involving interstate

commerce.” Hobbs Staffing Servs., Inc. v. Lumbermens Mut. Cas. Co., 168 N.C. App.

223, 226,

Related

Southland Corp. v. Keating
465 U.S. 1 (Supreme Court, 1984)
CSX Transportation, Inc. v. Easterwood
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Allied-Bruce Terminix Cos., Inc. v. Dobson
513 U.S. 265 (Supreme Court, 1995)
Doctor's Associates, Inc. v. Casarotto
517 U.S. 681 (Supreme Court, 1996)
Hunt Wesson Foods, Inc. v. Supreme Oil Company
817 F.2d 75 (Ninth Circuit, 1987)
City of Rose City v. Nutmeg Insurance Company
931 F.2d 13 (Fifth Circuit, 1991)
In Re the Appeal From the Civil Penalty
379 S.E.2d 30 (Supreme Court of North Carolina, 1989)
Goldstein v. American Steel Span, Inc.
640 S.E.2d 740 (Court of Appeals of North Carolina, 2007)
Internet East, Inc. v. Duro Communications, Inc.
553 S.E.2d 84 (Court of Appeals of North Carolina, 2001)
Cable Tel Services, Inc. v. Overland Contracting, Inc.
574 S.E.2d 31 (Court of Appeals of North Carolina, 2002)
Appliance Sales & Service, Inc. v. Command Electronics Corp.
443 S.E.2d 784 (Court of Appeals of North Carolina, 1994)
Hobbs Staffing Services, Inc. v. Lumbermens Mutual Casualty Co.
606 S.E.2d 708 (Court of Appeals of North Carolina, 2005)
Burke County Public Schools Board of Education v. Shaver Partnership
279 S.E.2d 816 (Supreme Court of North Carolina, 1981)
Cox v. Dine-A-Mate, Inc.
501 S.E.2d 353 (Court of Appeals of North Carolina, 1998)
Mark Group International, Inc. v. Still
566 S.E.2d 160 (Court of Appeals of North Carolina, 2002)
Veazey v. City of Durham
57 S.E.2d 377 (Supreme Court of North Carolina, 1950)
Full-Sight Contact Lens Corp. v. Soft Lenses, Inc.
466 F. Supp. 71 (S.D. New York, 1978)

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