King Carpentry v. 1345 K Street, SE, LLC

CourtDistrict of Columbia Court of Appeals
DecidedNovember 4, 2021
Docket19-CV-1162 & 20-CV-422
StatusPublished

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King Carpentry v. 1345 K Street, SE, LLC, (D.C. 2021).

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

Nos. 19-CV-1162 & 20-CV-0422

KING CARPENTRY, INC., APPELLANT

V.

1345 K STREET SE, LLC; ADI CONSTRUCTION OF VIRGINIA, LLC; GREAT AMERICAN INSURANCE COMPANY, APPELLEES.

Appeals from the Superior Court of the District of Columbia (CAB7636-18 & CAB7634-19)

(Hon. Fern Flanagan Saddler & Hon. Jason Park, Trial Judges)

(Argued September 16, 2021 Decided November 4, 2021)

Stephen M. Seeger, with whom Alexandra E. Busch was on the brief, for appellant.

Alexia Kent McClure, with whom Deanna L. Peters, of the bar of the State of Virginia, pro hac vice, by special leave of court, was on the brief, for appellee ADI Construction.

J. Andrew Baxter for appellee 1345 K St SE, LLC.

Eric G. Korphage for appellee Great American Insurance Company. 2

Before GLICKMAN, EASTERLY, and DEAHL, Associate Judges.

EASTERLY, Associate Judge: In these consolidated appeals, we analyze the

distinction between mandatory and permissive forum selection clauses. We also

examine the Subcontractor’s Lien statute, D.C. Code § 40-303.01 et seq. (2012

Repl.), to determine whether certain procedural requirements ensuring notice of

encumbrances on real property apply when a lien on the property has been released

and replaced with an undertaking. We conclude that the trial court dismissed King

Carpentry’s complaint based on an incorrect analysis of both of these issues in the

first order on appeal in 19-CV-1162, and we reverse and remand for further

proceedings consistent with this opinion. And because our reversal of the first

judgment strips it of any res judicata effect, we likewise reverse the second order on

appeal in 20-CV-422 dismissing King Carpentry’s complaint on res judicata

grounds.

I. Facts and Procedural History

1345 K Street SE, LLC, the owner and developer of the property at that

address in the District, hired ADI Construction of Virginia to serve as the general

contractor on a condominium project at that location. ADI hired King Carpentry as

a subcontractor for rough carpentry and framing. ADI and King Carpentry signed a 3

contract with a forum selection clause stating that the parties “consented to personal

jurisdiction and venue, for any action arising out of breach or threatened breach of

this Agreement in the Circuit Court in and for Fairfax County, Virginia.” During

the project, they had disagreements about the scope of work and compensation.

When King Carpentry did not get paid the amount it thought it was due, it filed a

Notice of Mechanic’s Lien against the development property with the District’s

Recorder of Deeds pursuant to a section of the District’s Subcontractor’s Lien

statute, D.C. Code § 40-303.03.

After the recordation of the mechanic’s lien, 1345 K Street SE and ADI filed

a “Consent Petition for Approval of Written Undertaking to Release Mechanic’s

Lien” pursuant to D.C. Code § 40-303.17; see also D.C. Code § 40-303.16. In the

consent petition, they asked the Superior Court to approve the substitution of a bond

issued to them by Great American Insurance Company (“GAIC”) as security for any

judgment against the property, 1 direct recordation of the undertaking, and order

1 The Bond, signed by representatives from 1345 K Street SE and ADI, acknowledged both the existence of King Carpentry’s mechanic’s lien and the ability under the District’s Subcontractor’s Lien statute to discharge the lien upon filing of an undertaking and bond. It then stated that: Effective upon approval . . . by the Superior Court of the District of Columbia and recordation of an undertaking by Principals with the Recorder of Deeds for the District of Columbia, in the event that any final judgment is entered by 4

“release [of] the [p]roperty from the lien filed by . . . King Carpentry.” The Superior

Court granted the petition and issued an order approving the undertaking and bond,

directing recordation, and “decree[ing] that upon the recording of such undertaking,

the property . . . shall forthwith stand released from the lien of Respondent King

Carpentry.”

King Carpentry subsequently filed a complaint in D.C. Superior Court,

alleging “Breach of Contract against ADI” and “Enforcement of Mechanic’s Lien

Against Undertaking against 1345 K St[reet SE], ADI, and GAIC.” ADI filed a

motion to dismiss the complaint 2 arguing that (1) the contract claim should be

dismissed because its contract with King Carpentry contained a forum selection

clause designating Fairfax County, Virginia as the exclusive forum to litigate

disputes and King Carpentry had filed his complaint in the District and (2) the

mechanic’s lien claim should be dismissed because King Carpentry had failed to

follow the requisite procedures of the Subcontractor’s Lien statute, specifically by

the Superior Court . . . adjudicating said lien to be valid and determining the amount which the same would have been enforceable against the property affected thereby, together with such costs and interest as may be awarded, shall be fully satisfied . . . . (emphasis added). 2 After 1345 K Street SE obtained the undertaking with ADI, ADI appeared to take the lead in litigating this matter in the trial court. Continuing in that role on appeal, ADI filed an appellee’s brief that 1345 K Street SE joined in full. 5

failing to file a notice of lis pendens with its complaint and by failing to notify other

lienors of the action. In opposition to the motion, King Carpentry argued that (1)

the forum selection clause was permissive and not mandatory, and (2) the procedures

that King Carpentry had allegedly failed to follow did not apply to suits such as King

Carpentry’s where the lien had been discharged prior to the initiation of a suit. The

trial court (Saddler, J.) granted ADI’s motion in a short order with only two

paragraphs of analysis that did not address King Carpentry’s arguments in any detail.

Following the trial court’s dismissal of King Carpentry’s complaint, King

Carpentry filed a second complaint, seeking a judgment against ADI and GAIC on

the amount of the bond issued by GAIC as security of any judgment against the

property. ADI and GAIC moved to dismiss on res judicata grounds, and the trial

court (Park, J.) granted the motion. King Carpentry timely appealed both orders.

II. Whether the Contract Claim was Properly Dismissed Pursuant to the Forum Selection Clause in the Contract

The trial court dismissed King Carpentry’s breach of contract claim against

ADI on the ground that King Carpentry and ADI “specifically negotiated the . . .

forum selection clause.” This court has held that forum selection clauses are

permissible so long as (1) the existence of such a clause is reasonably communicated 6

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King Carpentry v. 1345 K Street, SE, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/king-carpentry-v-1345-k-street-se-llc-dc-2021.