Merchants National Bonding, Inc. v. Hoffmann

CourtDistrict Court, M.D. Florida
DecidedAugust 1, 2025
Docket2:24-cv-01034
StatusUnknown

This text of Merchants National Bonding, Inc. v. Hoffmann (Merchants National Bonding, Inc. v. Hoffmann) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Merchants National Bonding, Inc. v. Hoffmann, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA FORT MYERS DIVISION

MERCHANTS NATIONAL BONDING, INC.,

Plaintiff and Counter- Defendant,

v. Case No. 2:24-cv-1034-JES-NPM

DAVID H. HOFFMANN, JERRILYN M. HOFFMANN, TIER ELECTRIC OF CENTRAL FLORIDA, INC., and HOFFMANN TIER ELECTRIC, LLC,

Defendants and Counter- Claimants.

OPINION AND ORDER This matter comes before the Court on Plaintiff Merchants National Bonding, Inc.’s (“Merchants” or “Plaintiff”) Motion to Strike Jury Trial Demand (Doc. #36) from Defendants’ Answer, Affirmative Defenses, and Counterclaim (“Answer”) (Doc. #21). Also before the Court is Merchants’ Motion to Dismiss Counterclaims II, V, VI, and VII, and Motion to Strike Jury Trial Demand (Doc. #38) from Defendants’ First Amended Counterclaim (“FACC”) (Doc. #35.) Defendants David H. Hoffmann (“Mr. Hoffmann”), Jerrilyn M. Hoffmann (“Mrs. Hoffmann”), Tier Electric of Central Florida, Inc. (“Tier”), and Hoffman Tier Electric, LLC (“HTE”) (collectively, “Defendants”) filed Responses in Opposition (Doc. #47, Doc. #48.) With leave of Court (Doc. #50), Merchants filed a Reply (Doc. #53.) For the reasons given below, the Motion to Strike Jury Trial Demand in Defendants’ Answer (Doc. #36) is GRANTED, and the Motion

to Dismiss and to Strike Jury Trial Demand in Defendants’ FACC (Doc. #38) is GRANTED IN PART and DENIED IN PART. I. Defendants were hired as electrical subcontractors for a construction project in Naples, Florida, by Suffolk Construction Company (“Suffolk”). The relationship with Suffolk was governed by a Subcontract Agreement (“Subcontract”). (Doc. #21-1.) Article 7 of the Subcontract required Defendants to execute and deliver performance and payment bonds worth $4.7 million to Suffolk. (Id. at 3, 6.) Tier obtained a Subcontract Payment Bond (“Payment Bond”) and Subcontract Performance Bond (“Performance Bond”) (collectively,

the “Bonds”) from Merchants. (Doc. #21-3.) Additionally, a General Application and Agreement of Indemnity (“GIA”) was executed where Defendants agreed to indemnify Merchants for liabilities, losses, and expenses caused by the execution or procurement of the Bonds. (Doc. #21-2, p. 3.) The relationship with Suffolk soured. Defendants allege that they were not at fault, and that Merchants initially agreed with that determination. Merchants later reversed course, Defendants claim, forcing Tier to sign a Performance Bond Release and Assignment (“Settlement”) by threatening to stop supporting its operations. (Doc. #21-5.) As part of the Settlement, Merchants paid Suffolk $1.8

million. (Id. at 3.) Merchants and Tier also agreed to forfeit $1.4 million owed by Suffolk. (Id. at 2–3.) Suffolk reduced the penal sum of the Performance Bond to $500,000 and agreed to release that Bond entirely upon Tier’s completion of certain remaining construction items. (Id. at 3.) If Tier’s completion of the remaining items was delayed, Suffolk could charge Tier $5,000 per day in Delay Damages.1 (Id. at 4.) In addition, Suffolk assigned to Merchants all of its claims against Tier relating to the Performance Bond. (Id. at 5.) The Settlement did “not releas[e]” any obligations under the “Payment Bond.” (Id. at 4.) Also relevant, Merchants, Tier, and Mr. Hoffmann executed a Promissory Note and Security Arrangement (the “Note”). (Doc. #21-

4.) The Note supplies “terms” that govern Tier’s payment of “all amounts for which [it] is obligated to indemnify [Merchants] under [the GIA].” (Id. at 2.) Payments are to be made in “monthly installments” of “$25,000” by the “26th" of each month. (Id.) Merchants may accelerate payments under the Note when a default

1 Suffolk later demanded $500,000 in liquidated delay damages based on Defendants’ alleged failure to timely complete the remaining items, which Merchants paid in exchange for a full release, discharge and cancellation of the Performance Bond. That agreement was memorialized in a Supplemental Performance Bond Release and Assignment (the “Supplement”). remains uncured after two contractual notice periods. (Id.) II. Merchants commenced this action for breach of contract,

asserting that all four Defendants breached their duty of indemnification under the GIA. (Doc. #1, pp. 11–12.) Defendants filed their Answer (Doc. #21), and more recently, their First Amended Counterclaim (“FACC”). (Doc. #35.) In thirteen counts, the FACC seeks declaratory relief and damages for various contract and tort claims. Merchants filed the pending Motion to Strike (Doc. #36) and Motion to Dismiss and Strike (Doc. #38), seeking the following relief: (a) the dismissal of Counterclaims II, V, VI, and VII as improper shotgun pleadings, or alternatively, a more definite statement under Rule 12(e); (b) the dismissal of Counterclaim VII with prejudice because Tier and Mr. Hoffmann lack standing to bring

that claim; (c) the striking of Defendants’ request for a jury trial for their answer, affirmative defenses, and counterclaims because Defendants waived their rights to a jury trial in the GIA and the Settlement. A. Shotgun Pleadings i. Arguments Merchants seeks to dismiss Counterclaims II, V, VI, and VII as impermissible “shotgun pleading[s].” (Doc. #38, p. 11.) Merchants asserts that Defendants “run afoul of the prohibition against commingling separate and distinct causes of action.” (Id.) The argument is as follows. Counterclaim II makes a single claim for declaratory relief involving “two separate contracts”:

the Note and the GIA. (Id.) Counterclaims V and VI seek declaratory relief for claims involving three separate contracts: the GIA, the Settlement, and the Note. (Id. at 11–12.) Counterclaim VII alleges a breach of contract claim involving “two separate and distinct contracts,” the Performance Bond and the Payment Bond, “with different terms, conditions, rights, and obligations.” (Id. at 12.) Additionally, not all Defendants are parties to each of those contracts. (Id.) Merchants concludes that it would be “[b]etter practice” to require those counterclaims to be repleaded “in separate and distinct causes of action,” or alternatively, the Court should require a more definite statement under Rule 12(e). (Id.)

As to Counterclaims II, V, and VI, Defendants respond that there is no “shotgun pleading” involved “because the matters pled involve contracts that are interrelated.” (Id. at 8.) As to Counterclaim VII, Defendants respond that “[t]here is no reason to distinguish” between the two Bonds in “separate counts because the point is the same” — Merchants “breached its duties under [both] bonds by treating Tier as being in default under the Subcontract [] when it was not.” (Id. at 10.) Defendants also assert that the Settlement “ma[de] no distinction between whether the amounts [were] being paid [from] one [Bond] or the other.” (Id.) Rather, the amounts drawn from each were reduced to a “lump sum” under the Settlement. (Id.) (citation modified). As such, separating

Counterclaim VII into two breach of contract claims is unnecessary. (Id.) ii. Analysis The “unifying characteristic” of all four types or categories of shotgun complaints is that they fail “to give the defendants adequate notice of the claims against them and the grounds upon which each claim rests.” Weiland v. Palm Beach Cnty. Sheriff’s Off., 792 F.3d 1313, 1321–23 (11th Cir. 2015). The Court concludes that Counterclaims II, V, and VI do not fall within the prohibition against shotgun pleading. However, as discussed below, clarity would be promoted by the repleading of Counterclaim VII. The Court begins with Merchants’ challenges to Counterclaims II,2 V,3 and VI4, all of which seek declaratory judgments.

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Merchants National Bonding, Inc. v. Hoffmann, Counsel Stack Legal Research, https://law.counselstack.com/opinion/merchants-national-bonding-inc-v-hoffmann-flmd-2025.