Hardypond Constr. v. R&G, Inc.

CourtSuperior Court of Maine
DecidedNovember 7, 2003
DocketCUMcv-03-418
StatusUnpublished

This text of Hardypond Constr. v. R&G, Inc. (Hardypond Constr. v. R&G, Inc.) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hardypond Constr. v. R&G, Inc., (Me. Super. Ct. 2003).

Opinion

STATE OF MAINE SUPERIOR COURT

CUMBERLAND, ss. CIVIL ACTION DOCKET NO. CV-03-418 JEG NT REC - CUA - 5 BONA HARDYPOND CONSTRUCTION HOY -1T AG 3uy 0 P | Ny yee Plaintiff, v. BONALD LC. icy ORDER ON PLAINTIFF'S Lavi oy MOTION TO STAY R&G, INC. AND TO COMPEL NOW be x ARBITRATION Defendant. ee 70085 FACTUAL BACKGROUND

This case involves two construction projects on which R&G, Inc. (“R&G”) was subcontractor to contractor Hardypond Construction (“Hardypond”). In both subcontracts between Hardypond and R&G, the parties made the following agreement.

With respect to any disputes between the Contractor and the Subcontractor arising under this Subcontract, the Subcontractor agrees that the Contractor, at its sole option and in its sole discretion, may elect to submit such disputes to arbitration in which such event all claims between the parties hereunder shall be subject to arbitration. Such election shall be evidenced by the filing of a demand for arbitration in accordance with the Construction Industry Arbitration Rules of the American Arbitration Association and such arbitration shall then be conducted in accordance with such rules. This agreement to arbitrate shall be specifically enforceable under the prevailing law. The award rendered shall be final and judgment may be entered upon the award by any court having jurisdiction thereof.

(PI.’s Mot. To Stay Case & to Compel Arb., Ex. A at 7 & Ex. Bat 7.)

On April 3, 2003, Plaintiff Hardypond filed a three-count complaint against Defendant in the Portland District Court and made a motion for attachment. On May 1, 2003, Defendant filed a counterclaim against Plaintiff and a third party complaint against the Town of Falmouth (“Falmouth”) and Carter’s Auto Service, Inc. (“Carter’s”). In addition, R&G filed a Notice of Removal, removing the case from the District Court to

the Superior Court. While the case was pending, R&G, Hardypond, Carter’s, and Falmouth entered into negotiations, which ultimately resulted in the dismissal of Carter’s and Falmouth from the suit and a decision by the parties to enter into a stipulation to bond off mechanics’ liens. On June 21, 2003, not long after the parties executed the Stipulation and agreed to the dismissal, the District Court denied Plaintiffs Motion for Attachment. On June 26, 2003, the stipulation was incorporated as an order signed by the District Court Judge. On August 19, 2003, the case was transferred to the Superior Court where a Scheduling Order was sent to the parties.

On September 2, 2003, Plaintiff Hardypond made a demand for arbitration. (Pl.’s Mot. To Stay Case & to Compel Arb., Ex. C.) However, Defendant R&G has indicated that it is not willing to proceed to arbitration.

DISCUSSION

When the facts upon which waiver is based are not in dispute, the determination of whether a party has waived its contractual right to arbitration is a question of law for

the court. Saga Communs. Of New England, Inc. v. Voornas, 2000 ME 156, § 7, 756 A.2d

954, 958; Doctor’s Assoc., Inc. v. Distajo, 107 F.3d 126, 130 (2nd Cir. 1997) (Distajo II).

Maine has adopted a strong policy favoring the enforcement of arbitration clauses. See

J.M. Huber Corp. v. Main-Erbauer, Inc., 493 A.2d 1048, 1050 (Me. 1985). While courts

that have addressed the issue of waiver have not reached an agreement on all the elements required to find a waiver, they do agree that the party seeking to compel

arbitration must, at a minimum, have undertaken a course of action “inconsistent with

its present insistence upon its contractual right to arbitration.” Voornas, J 12, 756 A.2d at 959.

Here, the parties have not undertaken a course of action inconsistent with their present demand for arbitration, as they have not litigated substantial issues going to the merits of the case. See id. (holding “[t]he relevant question is whether the parties have

7 litigated ‘substantial issues going to the merits’ of the arbitrable claims without any indication that, despite the dispute’s presence in court, a party intends to exercise its contractual right to arbitration.” (citations omitted)). Plaintiff rightfully asserts that its

Motion for Attachment was simply an attempt to preserve status quo. See Sweater Bee

by Banff, Ltd. v. Manhattan Industries, Inc., 754 F.2d 457, 463 (2nd Cir. 1985) (holding that defendants did not waive their right to compel arbitration by participating in discovery for two years and filing a motion to dismiss under Fed. R. Civ. P.12(b)(6));

compare Rush v. Oppenheimer & Co., 779 F.2d 885, 887-90 (2nd Cir. 1985) (holding that

defendants did not waive their contractual right to compel arbitration even though they had moved to dismiss the complaint, engaged in some discovery and failed to raise the

defense of arbitration in their answer), with Voornas, { 14, 756 A.2d at 960 (holding that

where plaintiff litigated substantial issue going to the merits of its breach of contract claim against the defendant in its motions for injunctive relief, and where plaintiff responded to the defendant’s motion for summary judgment on the merits without

indicating that the defendant was defending herself in the wrong tribunal, plaintiff

waived its right to compel arbitration), and Com-Tech Assoc. v. Computer Assocs. Int'l Ltd., 938 F.2d 1574, 1576 (2nd Cir. 1991) (holding that engaging in extensive depositions and defending motions for judgment on the pleadings and partial summary judgment constituted substantial litigation).

Similarly, Plaintiff's assertion that Defendant’s Stipulation to Bond Off the Mechanic’s Lien does not constitute substantial litigation is also meritorious. See

Buckminster v. Acadia Villiage Resort, Inc., 565 A.2d 313, 316 (holding that a general

arbitration clause did not operate as a waiver of plaintiff's statutory right to a mechanic’s lien).

In addition, Plaintiff's motion to compel arbitration must succeed because Defendant has not established that it has been prejudiced by Plaintiff’s decision to wait

2 to demand arbitration. “Prejudice... refers to the inherent unfairness—in terms of delay, expense, or damage to a party’s legal position—that occurs when the party’s opponent forces it to litigate an issue and later seeks to arbitrate that same issue.”

Voornas, { 17, 756 A.2d at 961 (citation and internal quotations omitted). Here,

Defendant is unable to establish any inherent unfairness. First, Defendant has not been substantially delayed by Plaintiff’s decision to wait five months from the time of filing its complaint to demand arbitration. In determining

whether Defendant has been prejudiced by delay, the court must focus on the impact of

the delay on Defendant. See Voornas, J 17 A.2 at 961; see also American Express Fin.

Advisors, Inc. v. Zito, 45 F. Supp. 2d 230, 234 (E.D.N.Y. 1999). While in Voornas the

Law Court held two and a half months of litigation amounted to an unfair delay,

Voornas, { 18 756 A.2d at 962, this case can be distinguished from Voornas. In Voornas,

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Related

Doctor's Associates, Inc. v. Emily Distajo
107 F.3d 126 (Second Circuit, 1997)
Buckminster v. Acadia Village Resort, Inc.
565 A.2d 313 (Supreme Judicial Court of Maine, 1989)
Saga Communications of New England, Inc. v. Voornas
2000 ME 156 (Supreme Judicial Court of Maine, 2000)
J.M. Huber Corp. v. Main-Erbauer, Inc.
493 A.2d 1048 (Supreme Judicial Court of Maine, 1985)
American Express Financial Advisors, Inc. v. Zito
45 F. Supp. 2d 230 (E.D. New York, 1999)

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