Extech Building Materials, Inc. v. E&N Construction, Inc.

CourtSupreme Court of New Jersey
DecidedDecember 2, 2025
DocketA-28-24
StatusPublished

This text of Extech Building Materials, Inc. v. E&N Construction, Inc. (Extech Building Materials, Inc. v. E&N Construction, Inc.) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Extech Building Materials, Inc. v. E&N Construction, Inc., (N.J. 2025).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

Extech Building Materials, Inc. v. E&N Construction, Inc. (A-28-24) (089720)

Argued September 9, 2025 -- Decided December 2, 2025

JUSTICE FASCIALE, writing for a unanimous Court.

In this appeal, the Court considers whether a single signature in a single agreement in which the signer binds a company as the principal debtor can simultaneously bind the signer in their personal capacity as guarantor.

To govern its sale and delivery of building materials to defendant E&N Construction, Inc. (E&N), plaintiff Extech Building Materials, Inc. (Extech) presented E&N with a two-page document entitled “CREDIT APPLICATION AND AGREEMENT.” Two E&N representatives signed, including defendant Joaquim G. Ferreira, the purported president of E&N. The paragraph above the signature lines stated that the signers “DO PERSONALLY GUARANTEE UNCONDITIONALLY, AT ALL TIMES, . . . THE PAYMENT OF INDEBTEDNESS . . . OF THE WITHIN NAME[D] FIRM.” Under each signature line, the pre-printed words “No Title” appeared. Accordingly, neither representative specified whether they signed the Credit Application as an E&N representative, individually, or both.

Extech supplied building materials pursuant to the parties’ agreement, but E&N failed to remit payment. Extech filed suit against defendants. The trial judge found that the agreement did not “make[] it clear that [the signers are] responsible as guarantors for the debt of . . . [E&N].” The judge granted summary judgment in favor of Ferreira. Extech appealed. The Appellate Division reversed, determining that genuine issues of fact regarding the intentions of the parties precluded summary judgment. The Court granted certification. 260 N.J. 63 (2025).

HELD: A valid personal guaranty of a company’s indebtedness requires the signer to unambiguously manifest their intent to be personally bound. There are multiple ways a corporate representative can unambiguously manifest an intent to personally guarantee an underlying agreement. Here, Ferreira did not unambiguously manifest an intent to personally guarantee the underlying corporate agreement.

1. A personal guaranty is an individual’s promise to a third party to answer for a principal’s debt or performance on an underlying contract, payable to the third party 1 only upon the principal’s default or failure to perform. A guaranty is fundamentally separate from the underlying contract, even if the two are written on the same paper or instrument or are contemporaneously executed. But a personal guaranty is still a type of contract, and its enforceability therefore depends -- as with any contract -- on mutual assent between the parties. New Jersey’s Statute of Frauds also requires that any assumption of liability for the debt of another be in writing and signed by the party assuming liability. N.J.S.A. 25:1-15. Once formed, contracts of this character are to be construed according to the strictest interpretation of the law. And as with all written agreements, any ambiguities in the language are interpreted most strongly against the entity which has prepared the form. (pp. 9-10)

2. The Court rejects Ferreira’s argument that his single signature cannot simultaneously bind both E&N, as principal, and himself, as guarantor, explaining that New Jersey law has not imposed a bright-line two-signature requirement. The Court also declines to impose such a requirement, holding instead that a valid personal guaranty of a company’s indebtedness requires the signer to unambiguously manifest their intent to be personally bound. An unambiguous manifestation of intent is required because a guaranty is a separate legal obligation that binds an individual who would otherwise be outside the scope of the underlying contract. The demand for clarity in this context flows from the general rule presuming that agents of a disclosed principal intend by their signature on a contract to bind only the principal. Such clarity also realizes the purpose of the Statute of Frauds as applied to personal guaranties. --- See N.J.S.A. 25:1-15. (pp. 10-16)

3. To unambiguously manifest an intent to personally guarantee an underlying agreement, the representative may (1) execute a separate personal guaranty agreement; (2) sign the underlying agreement once as a corporate representative and again individually; or (3) sign the underlying agreement a single time, provided that the agreement explicitly states the individual intends their single signature to bind both the company and the representative individually. The Court provides further guidance about each method. Ultimately, it is the signer’s intent that is dispositive, not the signature’s technical form; technical form is instructive only insofar as it allows courts to discern the requisite intent. Under longstanding legal principles governing personal guaranties, Ferreira did not unambiguously manifest an intent to personally guarantee the Credit Application. (pp. 16-19)

REVERSED. The trial court’s orders are REINSTATED.

CHIEF JUSTICE RABNER and JUSTICES PATTERSON, PIERRE-LOUIS, WAINER APTER, NORIEGA, and HOFFMAN join in JUSTICE FASCIALE’s opinion.

2 SUPREME COURT OF NEW JERSEY A-28 September Term 2024 089720

Extech Building Materials, Inc.,

Plaintiff-Respondent,

v.

E&N Construction Inc., Shawn Roney, ARC NJ, LLC, Travelers Casualty and Surety Company of America, and Liberty Mutual Insurance Company,

Defendants,

and

Joaquim G. Ferreira,

Defendant-Appellant,

ARC NJ, LLC,

Third-Party Plaintiff,

Elio Ferreira,

Third-Party Defendant.

1 On certification to the Superior Court, Appellate Division.

Argued Decided September 9, 2025 December 2, 2025

Zachary D. Wellbrock argued the cause for appellant (Anselmi & Carvelli, attorneys; Zachary D. Wellbrock and Marissa N. Kindberg, on the briefs).

Lisa J. Jurick argued the cause for respondent (Starr, Gern, Davison & Rubin, attorneys; Lisa J. Jurick and Jonathan J. Lerner, on the briefs).

JUSTICE FASCIALE delivered the opinion of the Court.

In this appeal, the parties dispute whether a corporate representative who

executed an underlying contract that obligated the company to pay for building

materials also agreed, in that same document, to personally guarantee the

supplier payment for the company’s indebtedness. The primary issue is

whether a single signature in a single agreement in which the signer binds a

company as the principal debtor can simultaneously bind the signer in their

personal capacity as guarantor.

We hold that a valid personal guaranty of a company’s indebtedness

requires the signer to unambiguously manifest their intent to be personally

bound. There are multiple ways a corporate representative can unambiguously

2 manifest an intent to personally guarantee an underlying agreement. The

representative may (1) execute a separate personal guaranty agreement; (2)

sign the underlying agreement once as a corporate representative and again

individually; or (3) sign the underlying agreement a single time, provided that

the agreement explicitly states their single signature binds both the company

and the representative individually.

We conclude that defendant Joaquim G. Ferreira did not unambiguously

manifest an intent to personally guarantee the underlying corporate agreement.

We therefore reverse the Appellate Division’s judgment and reinstate summary

judgment in Ferriera’s favor.

I.

A.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Russell v. Clark's Executors
11 U.S. 69 (Supreme Court, 1812)
Cruz-Mendez v. ISU/Insurance Services
722 A.2d 515 (Supreme Court of New Jersey, 1999)
Ligran, Inc. v. Medlawtel, Inc.
432 A.2d 502 (Supreme Court of New Jersey, 1981)
Atlantic Northern Airlines, Inc. v. Schwimmer
96 A.2d 652 (Supreme Court of New Jersey, 1953)
Looman Realty Corp. v. Broad Street Nat. Bank of Trenton
161 A.2d 247 (Supreme Court of New Jersey, 1960)
Caruso v. Ravenswood Developers, Inc.
767 A.2d 979 (New Jersey Superior Court App Division, 2001)
Conway v. 287 Corporate Center Associates
901 A.2d 341 (Supreme Court of New Jersey, 2006)
Leonard & Butler, PC v. Harris
653 A.2d 1193 (New Jersey Superior Court App Division, 1995)
Kotkin v. Aronson
815 A.2d 962 (Supreme Court of New Jersey, 2003)
In Re the Estate of Miller
447 A.2d 549 (Supreme Court of New Jersey, 1982)
NAT. WESTMINSTER BANK NJ v. Lomker
649 A.2d 1328 (New Jersey Superior Court App Division, 1994)
Brill v. Guardian Life Insurance Co. of America
666 A.2d 146 (Supreme Court of New Jersey, 1995)
Manahawkin Convalescent v. Frances O'neill (071033)
85 A.3d 947 (Supreme Court of New Jersey, 2014)
Ferguson Carpet Co. v. Schottenfeld
162 A. 534 (Supreme Court of New Jersey, 1932)
John H. Lyon & Co. v. Plum
69 A. 209 (Supreme Court of New Jersey, 1908)
Salzman Sign Co. v. Beck
176 N.E.2d 74 (New York Court of Appeals, 1961)
Sadler v. Young
75 A. 890 (Supreme Court of New Jersey, 1910)

Cite This Page — Counsel Stack

Bluebook (online)
Extech Building Materials, Inc. v. E&N Construction, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/extech-building-materials-inc-v-en-construction-inc-nj-2025.