Fraim v. American Sanitary Sales & Services, Inc.

50 Pa. D. & C.2d 307, 1970 Pa. Dist. & Cnty. Dec. LEXIS 178
CourtPennsylvania Court of Common Pleas, Delaware County
DecidedJune 17, 1970
Docketno. 13085 of 1969
StatusPublished

This text of 50 Pa. D. & C.2d 307 (Fraim v. American Sanitary Sales & Services, Inc.) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Delaware County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fraim v. American Sanitary Sales & Services, Inc., 50 Pa. D. & C.2d 307, 1970 Pa. Dist. & Cnty. Dec. LEXIS 178 (Pa. Super. Ct. 1970).

Opinion

deFURIA, J.,

By preliminary objections, defendant demurs to plaintiff’s amended complaint in trespass.

Plaintiff advances a novel claim.

Plaintiff was the general contractor of a school construction project for a school authority, with a time limit for completion. Defendant was the heating and ventilating subcontractor for the authority.

While we speak of general and subcontractor, more accurately plaintiff contracted with the authority for the general construction. A separate contract was awarded by the authority to defendant for heating and ventilating work and equipment.

There were other “subcontractors” for other phases of the work. Separate contracts for various phases of a construction project are required by law. Such public construction contracts are well known.

The novelty of plaintiff’s claim arises from his [308]*308claim in trespass against defendant for deliberately, intentionally and maliciously failing to timely complete defendant’s contract with the authority, thereby causing damage to plaintiff.

Plaintiff’s original complaint in assumpsit was before this court, at which time plaintiff alleged the violation by defendant of plaintiff’s third-party beneficiary rights. This court, on March 20, 1970, sustained defendant’s preliminary objections on the ground of lack of specificity, with leave to plaintiff to amend.

Unless specific terms of a contract create a third-party beneficiary relationship, under public construction contracts, the requirement that subcontractors cooperate with other subcontractors (and the general contractor) does not make the general contractor a third-party beneficiary entitled to delay damages upon subcontractor’s default: Van Cor, Inc. v. American Casualty Company of Reading, 417 Pa. 408, 208 A. 2d 267 (1965).

Plaintiff was obviously unable to amend by showing any express terms of the contract between defendant and the authority giving rise to plaintiff’s claim as a third-party beneficiary.

Plaintiff, consequently, adopted a new tack: he amended in trespass, without consent of defendant or order of court. Since defendant has not objected to the new “sound,” and since plaintiff could have instituted a new suit in trespass, we will consider the sufficiency of the amended complaint in trespass.

Does the amended claim in trespass set forth a cause of action?

We must distinguish between a “cause of action” which arises by operation of law, and the “pleading” of such a cause. In both complaints, plaintiff founds his claim upon a written document. Yet, he has never attached the written contract or contracts, even by [309]*309reference, nor has he set forth the specific and relevant terms thereof upon which he relies. If he has a valid claim, these deficiencies may be merely pleading errors.

Plaintiff’s basic claim is set forth in four paragraphs of the amended complaint, the essence of which are:

Paragraph 6: That defendant had a duty to the authority to perform its contract (defendant’s contract with the authority) by a certain date, which was prior to plaintiff’s own completion date with the authority. (In this paragraph, plaintiff merely recites a duty which defendant owed to the authority, not to plaintiff.)

Paragraph 8: That under defendant’s contract with the authority, “Defendant was responsible for all heating and ventilation construction without which the general contractor could not proceed under his contract with the Authority.” (Again, all plaintiff has averred is a duty of defendant to the authority. By reason of the necessary sequence of construction, plaintiff could not complete his work until defendant’s work was finished. Nothing has been added to plaintiff ’s complaint by this averment.)

Paragraph 9: That defendant had a duty to plaintiff to perform under the terms of its contract (defendant’s contract with the authority), and defendant knew that any negligent or intentional failure to perform would result in damage to plaintiff.

(Where is the duty to plaintiff revealed in defendant’s contract? Such a contractual duty has not been shown to exist.

Note that, here, plaintiff’s claim is based upon negligence, or by intentional failure to act, arising from a contract. But the contract terms are not set forth. Thus, the amended complaint still fails to plead a cause of action.)

Paragraph 10: That under defendant’s contract [310]*310with the authority, and the relationship of the parties, there is a duty to'plaintiff in meeting time requirements. (Again, plaintiff has failed to attach or cite the contract provisions, which obviously do not exist.) Plaintiff admitted at argument hereon that such provisions do not exist. However, plaintiff now raises a supposed duty arising from the relationship of the parties.

Does a duty of care devolve upon one to perform his independent construction contract so as not to delay another in the performance of a separate contract of the same project?

No law, decision or language has been cited to uphold this contention, which would have innumerable consequences. Under this theory, the negligent failure of a supplier (lumber, steel, stone) to furnish material to a contractor would make the supplier liable for the contractor’s delay in completion.

The effect of an intentional failure is discussed infra.

Paragraph 11: Defendant intentionally, willfully and maliciously refused to perform its duties to the plaintiff and to the authority, so as to willfully inflict damage upon plaintiff.

(As we have seen, no duty to plaintiff has been shown under defendant’s contract with the authority. Joining an existing duty (to the authority) with a nonexisting duty (to plaintiff) does not improve plaintiff ’s claim.)

The gravamen of plaintiff’s complaint, therefore, is that defendant intentionally delayed completion of its (own) contract with the authority, in order to damage plaintiff in his separate contract with the authority.

Does such a claim set forth a cause of action?

Free enterprise and competition have produced socially undesirable conduct by those who intentionally [311]*311interfere in the contractual relations of others, causing damage thereby. The courts have moved to protect certain contractual relationships from unwarranted interference.

But the courts have acted only where intentional interference in those contractual relations has been shown.

In Keifer v. Cramer, 356 Pa. 96, 51 A. 2d 694 (1947), the claim was that defendant maliciously interfered in a contract between the plaintiff and a third party, and that defendant had induced the third party not to pay plaintiff. It was held that a cause of action had been pleaded, but the verdict for plaintiff was reversed for failure to show any damages caused thereby.

In Bloom v. Devonian Gas & Oil Company, 397 Pa. 309, 155 A. 2d 195 (1959), the counterclaim set forth interference by plaintiff, who allegedly obtained a second strip mining lease from the owner, who had already leased to defendant.

See also Dora v. Dora, 392 Pa. 433, 141 A.

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Related

Glazer v. Chandler
200 A.2d 416 (Supreme Court of Pennsylvania, 1964)
Alabama Power Company v. Thompson
178 So. 2d 525 (Supreme Court of Alabama, 1965)
Bloom v. Devonian Gas & Oil Co.
155 A.2d 195 (Supreme Court of Pennsylvania, 1959)
Dora v. Dora
141 A.2d 587 (Supreme Court of Pennsylvania, 1958)
Keifer v. Cramer
51 A.2d 694 (Supreme Court of Pennsylvania, 1947)
Van Cor, Inc. v. American Casualty Co.
208 A.2d 267 (Supreme Court of Pennsylvania, 1965)
Padden v. Local No. 90 United Ass'n of Journeymen Plumbers
82 A.2d 327 (Superior Court of Pennsylvania, 1951)
Ross v. Wright
190 N.E. 514 (Massachusetts Supreme Judicial Court, 1934)

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Bluebook (online)
50 Pa. D. & C.2d 307, 1970 Pa. Dist. & Cnty. Dec. LEXIS 178, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fraim-v-american-sanitary-sales-services-inc-pactcompldelawa-1970.