Keystone Construction and Earthworks, LLC v. National Contractors, LLC

CourtDistrict Court, M.D. Pennsylvania
DecidedMarch 24, 2025
Docket4:24-cv-01614
StatusUnknown

This text of Keystone Construction and Earthworks, LLC v. National Contractors, LLC (Keystone Construction and Earthworks, LLC v. National Contractors, LLC) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Keystone Construction and Earthworks, LLC v. National Contractors, LLC, (M.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

KEYSTONE CONSTRUCTION AND No. 4:24-CV-01614 EARTHWORKS, LLC, (Chief Judge Brann) Plaintiff,

v.

NATIONAL CONTRACTORS, LLC, et al.,

Defendant.

MEMORANDUM OPINION

MARCH 24, 2025 I. BACKGROUND On September 24, 2024, Plaintiff Keystone Construction and Earthworks, LLC (“Keystone”), filed a three-count complaint against Defendants National Contractors, LLC (“National”) and Aldi, Inc. (“Aldi”).1 Counts 1 and 2—breach of contract and damages under the Pennsylvania Contractor and Subcontractor Payment Act—are against National, and Count 3—unjust enrichment—is against National and Aldi. Keystone filed an amended complaint on October 23, 2024, adding Merchants Bonding Company (“Mutual”) as a defendant and bringing one count against it for recovery on a surety bond.2

1 Doc. 1 (Compl.). On November 14, 2024, Aldi filed a motion to dismiss the unjust enrichment claim against it pursuant to Federal Rule of Civil Procedure 12(b)(6). The motion is

now ripe for disposition; for the reasons that follow, it is granted. Keystone is granted leave to amend. II. DISCUSSION

A. Motion to Dismiss Standard Under Federal Rule of Civil Procedure 12(b)(6), courts dismiss a complaint, in whole or in part, if the plaintiff fails to “state a claim upon which relief can be granted.” Following the landmark decisions of Bell Atlantic Corp. v. Twombly3 and

Ashcroft v. Iqbal,4 “[t]o survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’”5 The United States Court of Appeals for the Third Circuit has instructed that “[u]nder the pleading regime established by Twombly and Iqbal, a court

reviewing the sufficiency of a complaint must take three steps”: (1) “take note of the elements the plaintiff must plead to state a claim”; (2) “identify allegations that, because they are no more than conclusions, are not entitled to the assumption of

truth”; and (3) “assume the[] veracity” of all “well-pleaded factual allegations” and then “determine whether they plausibly give rise to an entitlement to relief.”6

3 550 U.S. 544 (2007). 4 556 U.S. 662 (2009). 5 Id. at 678 (quoting Twombly, 550 U.S. at 570). 6 Connelly v. Lane Constr. Corp., 809 F.3d 780, 787 (3d Cir. 2016). B. Facts Alleged in the Amended Complaint The facts alleged in the amended complaint, which this Court must accept as

true for the purposes of this motion, are as follows. Aldi contracted with National to build a grocery store in Williamsport, Pennsylvania.7 National, a general contractor, subcontracted with Keystone to perform work on the project.8 Under the subcontract, National agreed to pay

Keystone $1,634,750 for its work.9 Following a number of fully executed change orders, the value of the subcontract increased to $1,870,549.22.10 There was no direct contractual agreement between Aldi and Keystone. Keystone completed all

substantial work under the subcontract on December 11, 2023.11 Once the work was complete, Aldi made complete payment to National and opened the store.12 But National has not paid Keystone in full.13 Keystone claims that National has withheld payments due under its November and December 2023

pay applications totaling $442,386.76.14 Keystone argues that Aldi has been unjustly enriched because it is operating the store that Keystone helped build while Keystone has not been fully compensated.15

7 Doc. 6 ¶¶ 10, 12. 8 Id. ¶¶ 10, 13. 9 Id. ¶ 10. 10 Id. ¶ 11. 11 Id. ¶ 15. 12 Id. ¶¶ 20-22, 35, 44, 13 Id. ¶¶ 14, 17, 19-22. 14 Id. ¶¶ 19, 36. 15 Id. ¶¶ 50, 52-53, 56. C. Analysis “The doctrine of unjust enrichment contemplates that ‘a person who has been

unjustly enriched at the expense of another must make restitution to the other.’”16 To state a claim for unjust enrichment, a plaintiff must show: “(1) benefits were conferred on the defendant by the plaintiff; (2) appreciation of such benefits by the defendant; and (3) acceptance and retention of such benefits under such

circumstances that it would be inequitable for the defendant to retain the benefit without payment of value.”17 The key question is “whether the defendant has been unjustly enriched.”18

In the standard owner/general contractor/subcontractor relationship, an owner who has fully paid the general contractor is not unjustly enriched when the general contractor stiffs a subcontractor.19 In such a case, the owner’s receipt of the benefit is not “unjust”—it is just getting what it paid for.20 Requiring the owner to “‘pick up

[the general contractor’s] tab and pay twice for the same goods’ would itself be an

16 Am. & Foreign Ins. Co. v. Jerry’s Sport Center, Inc., 2 A.3d 526, 615 (Pa. 2010) (quoting Wilson Area Sch. Dist. v. Skepton, 895 A.2d 1250, 1254 (Pa. 2006)) (alterations omitted). 17 Liberty Mut. Grp., Inc. v. 700 Pharm., LLC, 270 A.3d 537, 554 (Pa. Super. Ct. 2022) (quoting Wilson v. Parker, 227 A.3d 343, 353 (Pa. Super. Ct. 2020)) (alterations omitted). 18 Id. 19 Restatement (Third) of Restitution and Unjust Enrichment § 25(2)(b) & cmt. b (Am. L. Inst., October 2024 Update) (“There is . . . no unjust enrichment if B [(property owner)] has paid the contract price to C [(general contractor)].”); see id. cmt. b, illus. 1. 20 EBC, Inc. v. Clark Bldg. Sys., Inc., 618 F.3d 253, 273-74 (3d Cir. 2010) (citing Meyers Plumbing & Heating Supply Co. v. West End Fed. Sav. & Loan Ass’n, 498 A.2d 966 (Pa. Super. Ct. 1985)); see Myers-Macomber Eng’rs v. M.L.W. Constr. Corp., 414 A.2d 357, 360-61 (Pa. Super. Ct. 1979) (enrichment not unjust when owner had paid project budget in full); Gee v. Eberle, 420 A.2d 1050, 1058-60 & n.8 (Pa. Super. Ct. 1980) (subcontractors could only partially recover based on the amount of project price that owner failed to pay). inequitable result.”21 So long as the owner has not directly induced or misled the subcontractor to work, it is not liable for the actions of the general contractor.22 This

standard fact pattern matches the case at bar, and Aldi—which the complaint alleges has paid all it owed—therefore cannot be liable on a theory of unjust enrichment.23 On Keystone’s allegations, Aldi has done nothing wrong—National is the one

who refuses to pay. But Aldi’s pockets are undoubtedly deeper than National’s. To Keystone’s chagrin, that is not a basis for liability.

21 EBC, 618 F.3d at 273-74 (quoting district court opinion, with which the panel “entirely agree[d]”). 22 D.A. Hill Co. v. Clevetrust Realty Invs., 573 A.2d 1005, 1009 (Pa.

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
EBC, Inc. v. Clark Building System, Inc.
618 F.3d 253 (Third Circuit, 2010)
Meehan v. Cheltenham Township
189 A.2d 593 (Supreme Court of Pennsylvania, 1963)
Myers-Macomber Engineers v. M. L. W. Construction Corp.
414 A.2d 357 (Superior Court of Pennsylvania, 1979)
D.A. Hill Co. v. Clevetrust Realty Investors
573 A.2d 1005 (Supreme Court of Pennsylvania, 1990)
Wilson Area School District v. Skepton
895 A.2d 1250 (Supreme Court of Pennsylvania, 2006)
Gee v. Eberle
420 A.2d 1050 (Superior Court of Pennsylvania, 1980)
Northeast Fence & Iron Works, Inc. v. Murphy Quigley Co.
933 A.2d 664 (Superior Court of Pennsylvania, 2007)
American & Foreign Insurance v. Jerry's Sport Center, Inc.
2 A.3d 526 (Supreme Court of Pennsylvania, 2010)
Sandra Connelly v. Lane Construction Corp
809 F.3d 780 (Third Circuit, 2016)
Wilson, A. v. Parker, C.
2020 Pa. Super. 13 (Superior Court of Pennsylvania, 2020)

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Keystone Construction and Earthworks, LLC v. National Contractors, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/keystone-construction-and-earthworks-llc-v-national-contractors-llc-pamd-2025.