Flatiron Constructors, Inc. v. TranSystem Corporation

CourtCourt of Appeals of South Carolina
DecidedDecember 10, 2025
Docket2024-000171
StatusUnpublished

This text of Flatiron Constructors, Inc. v. TranSystem Corporation (Flatiron Constructors, Inc. v. TranSystem Corporation) is published on Counsel Stack Legal Research, covering Court of Appeals of South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Flatiron Constructors, Inc. v. TranSystem Corporation, (S.C. Ct. App. 2025).

Opinion

THIS OPINION HAS NO PRECEDENTIAL VALUE. IT SHOULD NOT BE CITED OR RELIED ON AS PRECEDENT IN ANY PROCEEDING EXCEPT AS PROVIDED BY RULE 268(d)(2), SCACR.

THE STATE OF SOUTH CAROLINA In The Court of Appeals

Flatiron Constructors, Inc., Appellant,

v.

TranSystems Corporation, Respondent.

Appellate Case No. 2024-000171

Appeal From Horry County Kristi F. Curtis, Circuit Court Judge

Unpublished Opinion No. 2025-UP-416 Heard October 8, 2025 – Filed December 10, 2025

REVERSED AND REMANDED

Kenneth Jay Anthony, of Anthony Law, LLC, and Mason A. Goldsmith, Jr., of Elmore Goldsmith Kelley & deHoll, P.A., both of Greenville; and Robert Cimmino, Carter B. Reid, and Hanna Lee Blake, all of McLean, Virginia, all for Appellant.

Charles Daniel Atkinson and Michael B.T. Wilkes, both of Wilkes Atkinson & Joyner, LLC, of Spartanburg; and James Alexander Joyner, of Wilkes Atkinson & Joyner, LLC, of Charleston, all for Respondent. PER CURIAM: Flatiron Constructors, Inc. (Flatiron) appeals the trial court's grant of summary judgment on its claim for professional negligence against TranSystems Corporation (TSC). Flatiron sued TSC for negligent supervision and design of a parkway construction project in Horry County (the Project), claiming TSC's actions caused a delay in the Project and financial loss to Flatiron. On appeal, Flatiron claims the trial court erred in granting summary judgment because TSC failed to meet its initial burden of showing the "absence of evidence of a genuine issue of material fact" regarding its special relationship with Flatiron. It alternatively argues the trial court erred because Flatiron presented evidence demonstrating a genuine issue of material fact regarding their special relationship. Flatiron further argues the trial court erred by (1) prematurely dismissing Flatiron's additional claims before discovery was complete and (2) making factual findings regarding agency that were improper, unnecessary, and unfairly prejudicial. We reverse the grant of summary judgment and remand to the trial court.

1. We hold the trial court erred in granting summary judgment because there is a genuine issue of material fact as to whether there was a special relationship between the parties such that TSC owed Flatiron a duty. See Town of Hollywood v. Floyd, 403 S.C. 466, 477, 744 S.E.2d 161, 166 (2013) ("Summary judgment is proper if, viewing the evidence in a light most favorable to the nonmoving party, there is no genuine issue of material fact and the moving party is entitled to a judgment as a matter of law."); Thompkins v. Festival Ctr. Grp. I, 306 S.C. 193, 195-96, 410 S.E.2d 593, 594 (Ct. App. 1991) (holding that when a party makes a motion for summary judgment, "an adverse party may not rest upon the mere allegations or denials of his pleadings, but his response, by affidavits or as otherwise provided in this rule, must set forth specific facts showing that there is a genuine issue for trial" (quoting Rule 56(e), SCRCP)). We find further inquiry into the facts is necessary to determine the extent of the parties' relationship. Based on Tommy L. Griffin Plumbing and Heating Co. v. Jordan, Jones, & Goulding, Inc.1 and Cullum Mechanical Construction, Inc. v. South Carolina Baptist Hospital2, we must consider all of the facts and circumstances in determining whether a special relationship exists. See Tommy L. Griffin, 320 S.C. at 55-56, 463 S.E.2d at 89 ("Whether such a duty exists will depend on the facts and circumstances of each case."); Cullum, 344 S.C. at 433, 544 S.E.2d at 842 (explaining "it is a factual issue [as to] whether these circumstances give rise to a

1 320 S.C. 49, 463 S.E.2d 85 (1995). 2 344 S.C. 426, 544 S.E.2d 838 (2001). special relationship"). Although we acknowledge it is difficult from precedent to determine the exact facts and circumstances that create a special relationship, we find there was enough evidence presented in this case to establish a genuine issue of material fact as to this issue.

We acknowledge evidence was presented supporting TSC's argument that Travis Patrick was the Resident Construction Engineer (RCE) for the South Carolina Department of Transportation (SCDOT) and therefore Patrick had supervisory authority over the Project—not Martin Long, an engineer at TSC. For example, although there was an Organizational Chart listing Long as the RCE, it demonstrates Long reported to Patrick. The Standard Specifications for Highway Construction incorporated in the contract between Horry County and TSC (the TSC Contract) lists the RCE as a SCDOT official and provides that the RCE will decide all questions that arise and has the authority to suspend work or withhold payments. The Scope of Services document, also included in the TSC Contract, states SCDOT will provide daily supervision over the project and make final decisions and the project engineer provided by TSC will report directly to the SCDOT RCE. The Intergovernmental Agreement (the IGA) between Horry County, SCDOT, and the South Carolina Infrastructure Bank requires SCDOT to oversee all planning, design, engineering, and inspection of the Project. And, Patrick sent two separate emails in which he signed off as "Resident Construction Engineer, SCDOT."3

However, in the light most favorable to Flatiron, we find sufficient evidence was presented to create an issue of fact as to the relationship between the parties, and whether, based on that relationship, TSC owed a duty to Flatiron. See Tommy L. Griffin, 320 S.C. at 56, 463 S.E.2d at 89 (holding the engineer owed a duty to Griffin to not "negligently design or negligently supervise the project" where the engineer supervised the construction and had the right to inspect and stop construction). Hutcherson's affidavit stated TSC (1) "wielded substantial influence and power over" Flatiron; (2) "often made unilateral decisions in the field (without

3 We note that additional evidence was presented to the trial court in Flatiron's motion to reconsider. For example, in a February 2016 email a Flatiron project engineer and manager stated, "You would believe that [Long], the designated RCE has actual authority; that per the [Standard] Specifications he has express authority; and the position title alone provides apparent authority; but, in actuality he does not possess, and nor will he demonstrate, any authority . . . ." Additionally, Long also stated he was a consultant and the RCE would either be Patrick or Jason Thompson, SCDOT Bridge Engineer. first consulting [Horry County] or SCDOT)"; (3) "repeatedly exercised its right to reject or stop [Flatiron]'s work"; (4) oversaw construction activities; (5) coordinated and processed pay applications; and (6) inspected and rejected work. The Scope of Services portion of the TSC Contract states TSC will provide a project manager who is responsible for the daily operation, daily supervision, and administration of the Project. Specifically, we find there was evidence to support the fact that Long acted as RCE for SCDOT and used that power to make decisions for the Project. A December 2015 email from Long to Hutcherson stated, "The SCDOT has instructed [TSC] to have Flatiron stop all work on [a contract removal project.]" Thompson, who was copied on the email, responded to Long, stating his email was correct, "but the stop work call should have been made by the RCE. This type of scenario is what [TSC was] hired for." The Organizational Chart lists Long as the RCE. Moreover, TSC acknowledged in its brief that Long's title with TSC was RCE, that TSC is a representative of the SCDOT RCE, and that TSC had authority to reject defective material and suspend work.4

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Cite This Page — Counsel Stack

Bluebook (online)
Flatiron Constructors, Inc. v. TranSystem Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/flatiron-constructors-inc-v-transystem-corporation-scctapp-2025.