Kinetic Systems, Inc. v. IPS-Integrated Project Services, LLC and Lonza Biologics, Inc.

2024 DNH 071
District Court, D. New Hampshire·Decided September 3, 2024·No. 20-cv-1125-SM·Published·Cited by 1 cases

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Kinetic Systems, Inc.

v. Case No. 20-cv-1125-SM Opinion No. 2024 DNH 071 IPS-Integrated Project Services, LLC and Lonza Biologics, Inc.

O R D E R

In this dispute between a project contractor and its

subcontractor, defendant IPS-Integrated Project Services, LLC

(“IPS”) moves for summary judgment on Kinetic Systems, Inc.’s

(“Kinetics”) reinstated quantum meruit claim. Kinetics objects.

For the following reasons, the court grants the motion for

summary judgment.

Standard of Review

Summary judgment is appropriate when the moving party shows

that “there is no genuine dispute as to any material fact and

the movant is entitled to judgment as a matter of law.” Fed. R.

Civ. P. 56(a). “A genuine dispute is one that would permit a

rational factfinder to resolve the issue in favor of either

party, and a material fact is one that has the “potential to

affect the outcome of the suit under the applicable law.”

Gattineri v. Wynn MA, LLC, 63 F.4th 71, 84–85 (1st Cir. 2023) (internal quotation marks omitted). When resolving a motion for

summary judgment, the court views the record in the light most

favorable to the nonmoving party and draws reasonable inferences

in that party’s favor. 1 Deaton v. Town of Barrington, 100 F.4th

348, 355 (1st Cir. 2024).

Background

A. Procedural Background

Kinetics’s quantum meruit claim arises out of a commercial

construction project in Portsmouth, New Hampshire. Kinetics

brought claims against IPS for breach of contract and quantum

1 Kinetics continues to argue that it has no obligation to produce evidence in support of its quantum meruit claim because IPS has not carried its burden to show that it is entitled to summary judgment. IPS has properly invoked the summary judgment procedure on the merits of the quantum meruit claim, and it is Kinetics that bears the burden of showing that a genuine factual dispute exists to avoid summary judgment. See Celotex Corp. v. Catrett, 477 U.S. 317, 323 & 325 (1986) (holding that Rule 56 does not require “that the moving party support its motion with affidavits or other similar materials negating the opponent’s claim” and instead the moving party may carry its initial burden “by ‘showing’ - that is, pointing out to the district court - that there is an absence of evidence to support the nonmoving party’s case.”); see also Washington v. City of St. Louis, Mo., 84 F.4th 770, 774 (8th Cir. 2023) (holding that defendants “were free to rely on the absence of evidence supporting the plaintiff’s claims” in their motion for summary judgment). On the other hand, however, when the moving party seeks summary judgment based on a defense, it “bears the burden of proof and cannot attain summary judgment unless the evidence that it provides on that issue is conclusive.” Ouellette v. Beaupre, 977 F.3d 127, 135 (1st Cir. 2020) (internal quotation marks omitted).

2 meruit/unjust enrichment, seeking nearly $14 million for work it

did on that project as a subcontractor. The court previously

dismissed the quantum meruit/unjust enrichment claim. Doc. no.

15. Later, the court granted summary judgment in favor of IPS

on Kinetics’s breach of contract claim to the extent it was

based on amounts not paid on change proposals that were rejected

as untimely. Doc. no. 89.

Kinetics then moved to reinstate part of its previously-

dismissed quantum meruit claim, on the ground that in the

absence of a viable breach of contract claim for amounts not

paid in response to the untimely change proposals, it was

entitled to pursue an equitable remedy for those amounts. The

court allowed reinstatement over IPS’s objection. Doc no. 95.

IPS moved for reconsideration, raising defenses and challenging

the quantum meruit claim on the merits. The court directed IPS

to move for summary judgment, which it has done. Kinetics

objects to summary judgment and filed a supplemental objection,

as directed by the court. IPS filed a response to the

supplemental objection.

B. Factual Background

Kinetics’s work on the project was governed by two

contracts: the Early Mechanical Subcontract and the Process

Piping Subcontract. Each Subcontract required IPS to pay

3 Kinetics a lump sum for the work specified. 2 The Subcontracts

2 The parties do not provide a developed explanation of the operation of the lump-sum Subcontracts. One court has found that “there are two broad types of construction contracts: lump- sum and time-and-materials contracts.” United States for use of WESCO Distribution, Inc. v. Greenleaf Constr. Co., Inc., Case No. 14-cv-315-RGE-CFB, 2018 WL 10262170, at *3 (S.D. Iowa (Feb. 15, 2018). The two types operate as follows:

Lump-sum contracts are defined by a set contract price. The performing party is paid a lump sum for its performance and is not paid in direct relation to the time its employees work on a project or the materials it uses to complete a contract. Under an archetypical lump-sum contract, the performing party therefore suffers any cost-overruns. Lump-sum construction contracts provide the paying party a predictable cost for the contract, and are for that reason very attractive to general contractors hiring subcontractors for a complex project.

Time-and-materials contracts, by contrast, compensate the performing party in relation to the time its employees work and the materials it uses. Typically, when a performing party submits a time-and- materials bid, the party includes in the bid some mechanism to incorporate overhead costs and profit margin into its submitted labor and materials costs. In a time-and-materials contract, the paying party therefore suffers any cost-overruns. Time-and- materials construction contracts are rare where the contracting parties are beginning a project from scratch, but are more common where a performing party cannot easily estimate how much work must be completed. A time-and-materials contract may include a cap on total contract price or other contractual provisions to prevent cost overruns. For these reasons, a general contractor will typically exercise greater supervisory authority over a subcontractor in a time-and-materials contract than in a lump-sum contract.

Id.; see also Hall Contracting Corp. v. Entergy Servs., Inc., 309 F.3d 468, 475 (8th Cir. 2002); RMS of Wisc., Inc. v. S-K JV, No. 13-cv-1071, 2016 WL 2853539, at *2 (E.D. Wisc. May 16,

4 also included provisions for changing the scope of work,

increasing the time allowed and the amount to be paid, and

resolving disputes about changes and payments.

During its work on the project, Kinetics sought payment

from IPS under the Subcontracts through applications for

progress payments. It also sought payment for extra work not

covered by the Subcontracts through change proposals that were

governed by certain terms in the parties’ Subcontracts. The

amounts sought in change proposals that remain in dispute were

included in proposals not submitted within the time allowed

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Kinetic Systems, Inc. v. IPS-Integrated Project Services, LLC and Lonza Biologics, Inc., 2024 DNH 071 (D.N.H. 2024).

2024 DNH 071 (Kinetic Systems, Inc. v. IPS-Integrated Project Services, LLC and Lonza Biologics, Inc.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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