Johnson-Lancaster & Assoc., Inc. v. Veritas Constr. Servs., Inc.

2025 NY Slip Op 31909(U)
CourtNew York Supreme Court, New York County
DecidedMay 30, 2025
DocketIndex No. 452071/2024
StatusUnpublished

This text of 2025 NY Slip Op 31909(U) (Johnson-Lancaster & Assoc., Inc. v. Veritas Constr. Servs., Inc.) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Johnson-Lancaster & Assoc., Inc. v. Veritas Constr. Servs., Inc., 2025 NY Slip Op 31909(U) (N.Y. Super. Ct. 2025).

Opinion

Johnson-Lancaster & Assoc., Inc. v Veritas Constr. Servs., Inc. 2025 NY Slip Op 31909(U) May 30, 2025 Supreme Court, New York County Docket Number: Index No. 452071/2024 Judge: Kathleen Waterman-Marshall Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 452071/2024 NYSCEF DOC. NO. 40 RECEIVED NYSCEF: 05/30/2025

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. KATHLEEN WATERMAN-MARSHALL PART 31 Justice ---------------------------------------------------------------------------------X INDEX NO. 452071/2024 JOHNSON-LANCASTER AND ASSOCIATES, INC. MOTION DATE 02/26/2025 Plaintiff, MOTION SEQ. NO. 001 -v- VERITAS CONSTRUCTION SERVICES, INC., DECISION + ORDER ON MOTION Defendant. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 001) 17, 18, 19, 20, 21, 22, 23, 24, 34, 35, 36, 37 were read on this motion to/for DISMISS .

Upon the foregoing documents, defendant moves to dismiss the complaint in its entirety as beyond the contracted statute of limitations pursuant to CPLR § 3211(a)(1)(5) and (7). Plaintiff opposes. For the reasons set forth below, the motion to dismiss is granted.

This matter was administratively reassigned to Part 31 and thereafter referred to presumptive mediation. On May 2, 2025, the presumptive mediation part filed its conference report advising that a mediation conference was held, and the matter was not in the mediation part. This decision and order results.

Background Plaintiff Johnson-Lancaster and Associates (“JLA”) was a subcontractor for defendant Veritas Construction Services (“Veritas”). Pursuant to the subcontract agreement between the parties, JLA provided labor and materials for kitchen and cafeteria renovations in a Greenwood Lake elementary school. Before the project was completed, the relationship between the parties apparently broke down. Veritas contends that JLA caused certain construction delays, which led to Veritas ending their relationship following a payment on December 13, 2022. JLA contends that the December 13, 2022 payment was not the final payment, and that it is still owed for the work it completed.

Veritas moves to dismiss the action, contending that it is untimely pursuant to the parties’ contract. There is no dispute that under the subcontract the parties agreed to shorten the statute of limitations for disputes arising out of the agreement to one-year following the “final payment.” Veritas argues that it tendered the last payment to JLA on December 13, 2023, and JLA filed the instant complaint one year and five months after this final payment. Thus, Veritas contends the instant action is untimely. Veritas also contends that plaintiff’s non-contract claims (unjust enrichment, quantum meruit, breach of the implied covenant of good faith and fair dealing, book account, reasonable value of services provided, promise to pay, and prompt payment act) are 452071/2024 JOHNSON-LANCASTER AND ASSOCIATES, INC. vs. VERITAS CONSTRUCTION Page 1 of 4 SERVICES, INC. Motion No. 001

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duplicative of the contract claim and an attempt to circumvent the parties’ shortened limitations period; thus, Veritas seeks dismissal of the entire action.

JLA opposes dismissal contending that the limitations period was not triggered. JLA does not dispute that the parties’ agreement contains a one-year limitations period. However, JLA argues that “last payment” in the parties’ agreement means the final payment upon completion of the project, and because a final payment was not issued, and the project is not completed as of the date of this motion, the limitations period has yet to accrue.

Discussion As with all motions to dismiss under CPLR § 3211, the complaint should be liberally construed, the facts presumed to be true, and the pleading accorded the benefit of every possible favorable inference (see e.g. Leon v Martinez, 84 NY2d 83 [1994]).

Under CPLR § 3211(a)(1), a dismissal is warranted only if the documentary evidence submitted conclusively establishes a defense to the asserted claims as a matter of law” (id.; citing Heaney v Purdy, 29 NY2d 157 [1971]).

CPLR § 3211(a)(5), provides for dismissal of one or more causes of actions under the doctrine of collateral estoppel. The doctrine precludes a party from re-litigating, in subsequent actions, those issues which have been raised in a prior proceeding and decided against said party and has been characterized as “a narrower species of res judicata” (Ryan v New York Telephone Co., 62 NY2d 494, 500 [1984]).

On a motion to dismiss under § 3211(a)(7), the motion must be denied if, from the four corners of the pleadings, “factual allegations are discerned which taken together manifest any cause of action cognizable at law” (Polonetsky v Better Homes Depot, 97 NY2d 46, 54 [2001] [internal quotation omitted]). A complaint should not be dismissed so long as, “when the plaintiff’s allegations are given the benefit of every possible inference, a cause of action exists,” and a plaintiff may cure potential deficiencies in its pleading through affidavits and other evidence (R.H. Sanbar Projects v Gruzen Partnership, 148 AD2d 316, 318 [1st Dept 1989]). However, bare legal conclusions and factual allegations which are inherently incredible or contradicted by documentary evidence are not presumed to be true (Mark Hampton, Inc. v Bergreen, 173 AD2d 220 [1st Dept 1991]).

As an initial matter, there is no basis for dismissal under CPLR § 3211(a)(5), as the issues raised herein have not been raised in a prior proceeding or determined against plaintiff. Consequently, the Court considers the motion to dismiss under CPLR § 3211(a)(1) and (7).

Parties are free to agree to a shorter time period to commence an action than the period provided by the statute of limitations, provided that it is done so in writing, the limitations period is reasonable, and the provision is not so vague as to be unenforceable (Tamm Consulting v Cincinnati Ins. Co., 236 AD3d 533 [1st Dept 2025]; Executive Plaza, LLC v Peerless Ins. Co., 22 NY3d 511 [2014]; John J. Kassner & Co. Inc v City of New York, 46 NY2d 544, 551 [1979]). When these conditions are met, absent proof of overreaching or fraud, the shortened period to

452071/2024 JOHNSON-LANCASTER AND ASSOCIATES, INC. vs. VERITAS CONSTRUCTION Page 2 of 4 SERVICES, INC. Motion No. 001

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bring a claim will be enforced (id.; Matter of Incorporated Vil. of Saltaire v Zagata, 280 AD2d 547 [2d Dept 2001]).

There is no dispute that Article 37 of the parties’ subcontract agreement shortens the period to commence an action arising out of the parties’ agreement. That section of the agreement provides:

No action shall be brought against the General Contractor for any reason, unless commenced within one (1) year after receipt by the Subcontractor of the last Payment from the General Contractor.

Nor is there any dispute that a one-year period to bring an action for a construction contract is reasonable (Dart Mech. Corp. v. City of New York, 121 AD3d 452 [1st Dept 2014] [six-month limitations clause in construction contract enforceable]). The dispute on this motion to dismiss is limited to the meaning of the term “last payment,” and whether the December 16, 2022 payment constitutes the “last payment”. If the December 16, 2022 payment is the “last payment,” then the action will be untimely.

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Bluebook (online)
2025 NY Slip Op 31909(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/johnson-lancaster-assoc-inc-v-veritas-constr-servs-inc-nysupctnewyork-2025.