Laura Catena v. NVR Inc

CourtCourt of Appeals for the Third Circuit
DecidedAugust 30, 2024
Docket23-1642
StatusUnpublished

This text of Laura Catena v. NVR Inc (Laura Catena v. NVR Inc) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Laura Catena v. NVR Inc, (3d Cir. 2024).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ____________

No. 23-1642

____________

LAURA CATENA; GREGORY NOVOTNY

v.

NVR, INC, t/b/d/a Heartland Homes of PA, Appellant ____________

On Appeal from the United States District Court For the Western District of Pennsylvania (District Court No. 2-20-cv-00160) District Judge: Honorable Marilyn J. Horan ____________

Argued on June 3, 2024 ____________

Before: CHAGARES, Chief Judge, CHUNG and FISHER, Circuit Judges

(Filed: August 30, 2024)

Amit Agarwal [Argued] Holland & Knight 315 S Calhoun Street Suite 600 Tallahassee, FL 32301

Brendan Connors Holland & Knight 800 17th Street NW Suite 1100 Washington, DC 20006 Counsel for Appellant

Lydia A. Gorba [Argued] Strassburger McKenna Gutnick & Gefsky 444 Liberty Avenue Suite 2200, Four Gateway Center Pittsburgh, PA 15222

Kimberly S. Tague Eckert Seamans Cherin & Mellott 600 Grant Street 44th Floor, US Steel Tower Pittsburgh, PA 15219 Counsel for Appellee ____________

OPINION* ____________

CHUNG, Circuit Judge.

Upon discovering various defects in their newly constructed home, Plaintiffs

Laura Catena and Gregory Novotny sued Defendant NVR, Inc., for breach of express

warranty and for violating Pennsylvania’s Unfair Trade Practices and Consumer

Protection Law (“UTPCPL”). NVR unsuccessfully moved to dismiss and, later, to obtain

judgment as a matter of law. After trial, the jury found for Plaintiffs on both claims and

NVR now appeals the judgment as to the UTPCPL claim. We agree with NVR that the

District Court should have entered judgment for NVR on a portion of the UTPCPL claim,

and we will reverse the judgment and remand for further proceedings.

* This disposition is not an opinion of the full Court and, pursuant to I.O.P. 5.7, does not constitute binding precedent. 2 I. BACKGROUND

On September 10, 2017, Laura Catena and Gregory Novotny (“Plaintiffs”) entered

into a purchase agreement (“contract”) with NVR, Inc., to purchase property and

construct a home in Mars, Pennsylvania. The contract included an integration clause and

incorporated a Limited Warranty set forth in the homeowner’s manual. Plaintiffs claim

that they entered into the contract, relying on their viewing of a model home and on

representations NVR made in preliminary discussions, marketing materials, and on its

website (“extra-contractual statements”), including that they were purchasing a luxury

home (“luxury statements”).

After the home was built, Plaintiffs noticed various defects in the home, which

they alleged breached the Limited Warranty as well as extra-contractual promises, such

as the luxury statements. Plaintiffs sued NVR asserting claims for breach of a written

contract, breach of express and implied warranties, and violation of the UTPCPL. In

their Complaint, Plaintiffs asserted that NVR violated the UTPCPL under three

provisions of the statute: failing to comply with the terms of any written guarantee or

warranty, 73 Pa. Stat. § 201-2(4)(xiv) (the “warranty portion” of their UTCPCL claim);

making repairs, improvements, or replacements on tangible, real or personal property of a

nature or quality inferior to or below the standard of that agreed to in writing, id. § 201-

2(4)(xvi) (the “repair portion”); and engaging in fraudulent or deceptive conduct by

promising they would receive a luxury home, which created a likelihood of confusion or

3 of misunderstanding, id. § 201-2(4)(xxi) (the “catch-all portion”). Plaintiffs also

requested treble damages under the UTPCPL. NVR moved to dismiss the Complaint

asserting, among other things, that Plaintiffs’ UTPCPL claim was barred by the gist-of-

the-action doctrine. The District Court rejected the argument, concluding that the gist-of-

the-action doctrine did not bar the claim, but partially granted the motion on different

grounds and allowed Plaintiffs to amend. Plaintiffs filed an Amended Complaint shortly

thereafter.

The case proceeded to trial and NVR moved for judgment as a matter of law on

each claim, pursuant to Federal Rule of Civil Procedure 50, after Plaintiffs rested their

case. NVR argued, among other things, that the luxury statements were nonactionable

puffery as a matter of law and that extra-contractual statements could not be justifiably

relied upon per the contract’s integration clause. The District Court rejected these

arguments but granted the motion in part for other reasons and dismissed all claims

except for the breach of limited warranty and UTPCPL claims.

After resting its case, NVR renewed its motion for judgment as a matter of law

and again argued that the luxury portion failed as a matter of law because Plaintiffs could

not reasonably rely upon nonactionable puffery nor upon extra-contractual statements.

The District Court denied the motion and permitted the jury to deliberate upon all

portions of the UTPCPL claim. The District Court further noted that if the jury were to

find in favor of Plaintiffs, it would schedule a hearing on the treble damages and cost and

fees portion of the UTPCPL claim. The parties and the District Court agreed that each

4 party would get thirty days to brief that issue.

On September 22, 2022, the jury found for Plaintiffs on all three portions of their

UTPCPL claim. On the verdict slip, the jury indicated that it found that NVR violated

the UTPCPL under each provision alleged and awarded $122,585.20 in damages without

specifying the amount of damages attributable to each portion of that claim. Appendix

(“App.”) 562–63. The jury also found that NVR breached its Limited Warranty and

awarded damages of $23,877.20 for that claim. Shortly after dismissing the jurors, the

District Court reiterated that it would issue “an order directing for a briefing … on the

counsel fee cost and the [treble] damage aspect of [the] case,” allowing thirty days for

each party to brief the issue. Plaintiffs’ Supplemental Appendix (“Pls. Supp. App.”) 723.

The same day, the District Court entered judgment in favor of Plaintiffs reflecting the

damages awarded by the jury. The District Court also entered a text order directing

Plaintiffs to file a “Petition/Motion as regards additional remedies under the UTPCPL on

or before October 24, 2022.”1 Dist. Ct. Dkt., ECF No. 83.

On October 20, 2022, NVR filed another unsuccessful Rule 50 motion for

judgment as a matter of law (and moved in the alternative, for a new trial pursuant to

Rule 59(e)). Plaintiffs filed their petition for treble damages on October 24, 2022, styling

it as a motion to alter the judgment under Federal Rule of Civil Procedure 59(e),2 which

1 This deadline was four days past the deadline for filing motions to amend the judgment per Federal Rule of Civil Procedure 59(e). Fed. R. Civ. P. 59(e) (motions to amend must be filed “no later than 28 days after the entry of the judgment.”). 2 This would be untimely under Rule 59(e), as courts have no authority to extend the 28-day deadline. Fed. R. Civ. P.

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Laura Catena v. NVR Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/laura-catena-v-nvr-inc-ca3-2024.