Freeman v. Hilton

90 Va. Cir. 182
CourtNorfolk County Circuit Court
DecidedApril 17, 2015
DocketCase No. (Civil) CL13-5903
StatusPublished
Cited by1 cases

This text of 90 Va. Cir. 182 (Freeman v. Hilton) is published on Counsel Stack Legal Research, covering Norfolk County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Freeman v. Hilton, 90 Va. Cir. 182 (Va. Super. Ct. 2015).

Opinion

By Judge David W. Lannetti

Today, the Court rules on the Demurrer filed by Defendant Atlantic Blueridge Elevator Company (“Atlantic”). The three issues before the Court on demurrer are: (1) whether Plaintiff Cheryl Freeman sufficiently alleged a breach of contract claim; (2) whether Freeman can claim third-party beneficiary status on the contract (“the Contract”) between Atlantic and Doubletree by Hilton (“Doubletree”); and (3) whether the damages Freeman seeks are recoverable under the Contract. The Court finds that Freeman failed to sufficiently plead a breach of contract claim and, therefore, sustains the demurrer in that regard. The Court finds that, based on her allegations and the Contract, Freeman has not sufficiently pleaded her third-party beneficiary status; the Court, therefore, sustains the Demurrer as to her third-party beneficiary claim. The Court further finds, based on the allegations in the Third Amended Complaint, that tort damages are unavailable to a contractual third-party beneficiary, and the Contract’s limitation of liability clause bars Freeman from recovering consequential damages on her breach of contract claim; the Court, therefore, sustains the Demurrer as to the contract damages issue.

[183]*183 Background

Freeman filed suit against Doubletree and Atlantic alleging claims of negligence and breach of contract arising out of an incident that occurred in one of Doubletree’s hotels on June 26, 2012. Freeman was on a hotel elevator when the elevator “became disabled and stopped between two floors.” (Third Am. Compl. ¶ 9.) Doubletree employees allegedly assisted in opening the elevator door and encouraged Freeman and other passengers to jump several feet from the elevator to the hotel floor below. (See id. ¶¶ 11-14,17,19.) Freeman alleges that she jumped from the elevator and, upon landing, her “knees buckled and she fell onto the floor,” causing personal injuries. (Id. ¶ 26.)

Pursuant to the Contract, Atlantic agreed to repair and maintain the hotel elevators. (See generally Third Am. Compl. Ex. A.) Freeman alleges, inter alia, that she is a third-party beneficiary of the Contract and that, based on that capacity, Atlantic is liable to her for breach of contract as a result of Atlantic’s “failure to properly and reasonably maintain and repair” the elevator. (Id. at 9.)

The Court has thrice granted Freeman leave to file an amended complaint. On December 30, 2013, and May 30, 2014, leave was granted for good cause shown. The parties subsequently were before the Court on November 20, 2014, to hear Atlantic’s Demurrer to the Second Amended Complaint. There, Atlantic demurred on three grounds: (1) Freeman’s failure to allege duties of Atlantic to support a claim of negligence; (2) Freeman’s assumption of risk in jumping from the elevator; and (3) Freeman’s failure to allege sufficient facts to support a breach of contract claim against Atlantic. (Dem. to Second Am. Compl. 3-5.) The Court, in its December 4, 2014, ruling, overruled the demurrer on the negligence and assumption of risk grounds and sustained the demurrer on the breach of contract ground. The Court granted Freeman leave to amend — once again — regarding the breach of contract claim.

Most recently, the parties were before the Court on March 5, 2015, for a hearing on Atlantic’s Demurrer to the Third Amended Complaint. The Court allowed the parties to file post-hearing supplemental briefs. The issue now before the Court is whether there is merit to Atlantic’s Demurrer to the Third Amended Complaint.

Positions of the Parties

A. Atlantic’s Demurrer

Atlantic demurred to the Third Amended Complaint, arguing three main points: (1) Freeman fails to sufficiently plead that Atlantic breached the Contract; (2) Freeman fails to sufficiently plead a claim for which she can recover as a third-party beneficiary of the Contract between Atlantic and [184]*184Doubletree; and (3) the damages allegedly caused by Doubletree employees are not contract damages that either were foreseeable or arose from the intervention of special circumstances ordinarily predictable by Atlantic. (Dem. to Third Am. Compl. 2-4.)

B. Atlantic’s Brief in Support of Demurrer

Atlantic uses its Brief in Support of Demurrer to bolster the three legal arguments in its Demurrer. First, Atlantic addresses the issue of failure to sufficiently plead a breach of contract claim by asserting that Freeman fails to identify “which express term of the contract was breached.” (Br. in Supp. of Dem. 3.) Next, Atlantic states that Freeman did not “plead facts sufficient to find that Atlantic has assumed an obligation for the benefit of [Freeman],” concluding that Freeman does not point to any contract language that identifies her or any other third parties as intended beneficiaries of the Contract. (Id. at 3-4.) Finally, Atlantic articulates that the contract damages sought by Freeman are “specifically excluded pursuant to the contract,” so Freeman cannot recover them. (Id. at 5.)

C. Atlantic’s Supplemental Brief in Support of Demurrer

Atlantic’s Supplemental Brief in Support of Demurrer focuses on the issues of whether Freeman sufficiently pleaded that she is a third-party beneficiary of the Contract and whether Freeman seeks appropriate damages. (Supplemental Br. in Supp. 1-2.) Atlantic cites Ogunde v. Prison Health Services, 274 Va. 55, 645 S.E.2d 520 (2007), for the proposition that a contract must “clearly and definitely” identify any third-party beneficiaries and contends that the Contract here does not “clearly and definitely” contemplate Freeman or any others as third-party beneficiaries. (Id. at 2.) Atlantic further argues that the Contract specifically limits liability such that it would not be responsible for any loss “by any cause beyond [Atlantic’s] reasonable control, and in no event shall [Atlantic] be liable for consequential damages.” (Id.)

D. Freeman’s Brief in Response to Demurrer

Freeman contends that the Contract contemplated hotel invitees as intended beneficiaries and that she, therefore, was a third-party beneficiary of the Contract. (Br. in Resp. 1-2.) In support of her argument, Freeman — as Atlantic — cites Ogunde. (Id. at 2.) Freeman also challenges Atlantic’s contention that the Contract does not contemplate the recovery of consequential damages. (Id. at 3.)

[185]*185 Analysis

A. Legal Standard

A demurrer tests the legal sufficiency of the claims stated in the pleading challenged. Dray v. New Mkt. Poultry Prods., Inc., 258 Va. 187, 189, 518 S.E.2d 312, 312 (1999). The only question for the court to decide is whether the facts pleaded, implied, and fairly and justly inferred are legally sufficient to state a cause of action against the defendant. Thompson v. Skate Am., Inc., 261 Va. 121, 128, 540 S.E.2d 123, 126-27 (2001).

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90 Va. Cir. 182, Counsel Stack Legal Research, https://law.counselstack.com/opinion/freeman-v-hilton-vaccnorfolk-2015.