Joe Iskra and Rani Singh v. Bear Roofing, LLC (Appeal from Jefferson Circuit Court: CV-15-902590).

CourtSupreme Court of Alabama
DecidedJune 14, 2024
DocketSC-2023-0524
StatusPublished

This text of Joe Iskra and Rani Singh v. Bear Roofing, LLC (Appeal from Jefferson Circuit Court: CV-15-902590). (Joe Iskra and Rani Singh v. Bear Roofing, LLC (Appeal from Jefferson Circuit Court: CV-15-902590).) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joe Iskra and Rani Singh v. Bear Roofing, LLC (Appeal from Jefferson Circuit Court: CV-15-902590)., (Ala. 2024).

Opinion

Rel: June 14, 2024

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is printed in Southern Reporter.

SUPREME COURT OF ALABAMA OCTOBER TERM, 2023-2024

_________________________

SC-2023-0524 _________________________

Joe Iskra and Rani Singh

v.

Bear Roofing, LLC

Appeal from Jefferson Circuit Court (CV-15-902590)

STEWART, Justice.

Joe Iskra and Rani Singh ("the Iskras") appeal from a judgment of

the Jefferson Circuit Court ("the trial court") entered in favor of Bear SC-2023-0524

Roofing, LLC ("Bear"). The Iskras claim that they were intended third-

party beneficiaries of a contract between Bear and Kenneth Vinoski, that

Bear breached the contract and an express warranty associated

therewith, and that Bear negligently performed the contracted-for

repairs to a house the Iskras were purchasing from Vinoski. The trial

court entered a summary judgment against the Iskras and in favor of

Bear on each of the Iskras' claims. We reverse and remand.

Facts and Procedural History

The Iskras entered into a contract with Vinoski to purchase a

house, and they hired A.Q.I. Home Inspection Services, Inc. ("AQI"), to

inspect the house for any deficiencies before closing on the sale of the

house. AQI discovered evidence of water intrusion in the attic near the

front of the house, documented that discovery in an inspection report,

and submitted the inspection report to the Iskras. The Iskras requested

that Vinoski repair the source of the leak before closing on the sale of the

house, and Vinoski reached out to Bear for consultation. According to

Dustin Stanfield, Bear's corporate representative and president, Bear

was made aware that Vinoski was selling the house and that the source

2 SC-2023-0524

of the leak needed to be fixed because it was in a written inspection

report, though Bear never saw the inspection report.

It is undisputed that Vinoski entered into a contract with Bear to

repair the source of the leak. 1 According to Stanfield, Bear keeps a

written contract for every job performed. However, none of the parties

have provided the contract for the work to be performed. The only

evidence memorializing the agreement between Bear and Vinoski is the

receipt for the work performed by Bear, which speaks to applying

sealants and references a "Bear Tough" warranty that, Bear's website

states, "[covers the new homeowners] if [Vinoski] sells [his] house during

the warranty period." The receipt does not mention the Iskras, the

inspection report, or that Vinoski was selling the house. Stanfield

explained in an affidavit that the "Bear Tough" warranty does not

automatically transfer but, instead, will transfer through a process that

"requires the home-owner to ask us to transfer the warranty, and also

requires the home-owner to give us the name and contact information of

the intended buyer." Bear's warranty, as described on its website, does

1It is disputed, however, whether Bear repaired what it determined

needed to be fixed or whether Vinoski requested specific repairs.

3 SC-2023-0524

not mention that transfer process. Neither the Iskras nor Vinoski ever

requested that the warranty be transferred.

The Iskras allege that, a few weeks after they closed on the sale of

the house and moved in, they observed a leak in the same location where

the inspection report had noted evidence of water intrusion. The Iskras

spoke with a representative from Bear to request a quote for repairs, but

when they mentioned the warranty to the representative, the

representative responded that there was no warranty. The Iskras hired

a different roofing company to repair the leak and associated damage.

The Iskras filed a complaint in the trial court against Bear, among others,

alleging that Bear had breached the contract, and the associated express

warranty, that Bear had entered into with Vinoski and that Bear had

negligently performed the contracted-for repairs. Bear moved for a

summary judgment as to each of the Iskras' claims, arguing that Bear

had never intended to benefit the Iskras, that the warranty had never

been transferred to the Iskras, and that Bear had owed no duty to the

Iskras, as prospective purchasers of Vinoski's house.

On February 7, 2018, the trial court entered a summary judgment

in favor of Bear. In its judgment, the trial court reasoned:

4 SC-2023-0524

"Even though the Defendant Bear Roofing contends that summary judgment is due to be granted because the [Iskras] have not proven that a genuine issue of material fact exists on [their] claims for negligence/wantonness and breach of warranty …, the Court will first turn its attention to the issue of breach of contract. The [Iskras] contend[] that they are Third Party Beneficiaries to the contract between the Defendants Ken Vinoski and Bear Roofing.

"A non-signatory party claiming that he is an intended third-party beneficiary to a contract between other signatory parties must prove (i) that both parties intended, upon execution of the contract, to bestow a DIRECT benefit upon the third-party, and (ii) that the intention on the part of both contracting parties was present at the moment that the contract was formed. Ex parte Stamey, 776 So. 2d 85, 92 (Ala. 2000); Weathers Auto Glass, Inc. v Alfa, 619 So. 2d 1328, 1329 (Ala. 1993); Cooks Pest Control v. Boykin, 807 So. 2d 524 (Ala. 2001). The Defendant Bear Roofing denies that it had any intention of bestowing a benefit upon any person other than Ken Vinoski.

"According to law the burden shifts to the [Iskras] to provide substantial evidence to the contrary, i.e., evidence that Defendant Bear actually did intend to bestow a direct benefit to the [Iskras] at the moment defendant Bear Roofing contracted with Ken Vinoski. The [Iskras] have not produced any such evidence.

"Further, Alabama law states that when analyzing the intent of the contracting parties, the courts should examine only the language of the contract in question. Id.

"It is undisputed that the contract between Vinoski and Bear does not mention or refer to the [Iskras]. Indeed, the invoice/receipt, which represents the only contract between Bear and Vinoski, is silent as to the Iskras. Moreover, Mr. Vinoski states that he did not reveal to Bear Roofing the

5 SC-2023-0524

identity of the party purchasing his home but only instructed [Bear] to do 'what was necessary to fix it.' The statements made by Vinoski do not convey that a buyer had signed a purchase agreement. There is no evidence that Vinoski referenced the Iskras, or that he mentioned that the repairs were a contingency to his contract to sell to the Iskras. No evidence was presented to show that Bear Roofing intended for anyone to receive the benefit of [its] work performance other than Vinoski.

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Joe Iskra and Rani Singh v. Bear Roofing, LLC (Appeal from Jefferson Circuit Court: CV-15-902590)., Counsel Stack Legal Research, https://law.counselstack.com/opinion/joe-iskra-and-rani-singh-v-bear-roofing-llc-appeal-from-jefferson-ala-2024.