Orlando Health, Inc. v. HKS Architects, Inc.; HKS Architects, Inc. v. BBM Structural Engineers, Inc.

CourtDistrict Court, M.D. Florida
DecidedDecember 17, 2025
Docket6:24-cv-00693
StatusUnknown

This text of Orlando Health, Inc. v. HKS Architects, Inc.; HKS Architects, Inc. v. BBM Structural Engineers, Inc. (Orlando Health, Inc. v. HKS Architects, Inc.; HKS Architects, Inc. v. BBM Structural Engineers, Inc.) 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
Orlando Health, Inc. v. HKS Architects, Inc.; HKS Architects, Inc. v. BBM Structural Engineers, Inc., (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ~ ORLANDO DIVISION ORLANDO HEALTH, INC., Plaintiff, Vv. Case No. 6:24-cv-693-JA-LHP HKS ARCHITECTS, INC., Defendant.

HKS ARCHITECTS, INC., Third-Party Plaintiff, v. BBM STRUCTURAL ENGINEERS, INC., Third-Party Defendant.

ORDER This breach-of-contract action! arises from the design and construction of

a six-story hospital and supporting departments in Lake Mary, Florida.

This Court has subject-matter jurisdiction under 28 U.S.C. § 1832 based on diversity of citizenship. Plaintiff, Orlando Health, Inc., is a citizen of Florida, and Defendant/Third-Party Plaintiff, HKS Architects, Inc., is a citizen of Texas. HKS’s claims against the Third-Party Defendant, BBM Structural Engineers, Inc., fall within this Court’s supplemental jurisdiction under 28 U.S.C. § 13867(a). Orlando Health has not asserted any claims against BBM; if it had, the Court would lack jurisdiction over those claims because BBM is, like Orlando Health, a citizen of Florida. See 28 U.S.C. § 13867(b).

Orlando Health, Inc. contracted HKS Architects, Inc. (HKS) to serve as architect of record and to be responsible for the planning, architectural, and engineering services—including structural engineering services—for the design and construction of the hospital. HKS then subcontracted BBM Structural Engineers, Inc. (BBM) to provide the structural engineering services for the project. During construction of the hospital, various structural defects became obvious. These defects—which were determined to be design defects rather than construction defects—were serious, requiring immediate repairs before completion of the hospital. Orlando Health eventually filed this lawsuit to

recover from HKS the costs of those repairs. And HKS has filed a third-party complaint against BBM, alleging that BBM is the responsible party because it committed the structural design errors. Orlando Health now moves for summary judgment on all eleven of HKS’s affirmative defenses, arguing that some are legally insufficient and that others

are unsupported by the evidence. (Doc. 127). HKS has not responded to the motion, and its time for doing so has passed. See M.D. Fla. Local R. 3.01(c); (see also Doc. 20 at 5). Upon due consideration, Orlando Health’s motion for entry of summary judgment on HKS’s affirmative defenses must be granted. I. Legal Standard Summary judgment shall be granted if the moving party “shows that

there is no genuine dispute as to any material fact and the” moving party “is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). When the plaintiff moves for entry of summary judgment on the defendant’s affirmative defenses, the plaintiff “is not required to ‘support its motion with affidavits or other similar material negating the” affirmative defenses. United States v. Four Parcels of Real Prop. in Greene & Tuscaloosa Cntys., 941 F.2d 1428, 14387 (11th Cir. 1991) (emphasis in original) (quoting Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986)). Instead, because the defendant “has the burden of proof at trial”

on its affirmative defenses, Four Parcels, 941 F.2d at 1437, the “defendant has the initial burden of... showing that the” affirmative defense is applicable, Blue Cross & Blue Shield v. Weitz, 913 F.2d 1544, 1552 (11th Cir. 1990). While “summary judgment is appropriate where the defendant fails to

come forward with” sufficient evidence to support an affirmative defense, Office of Thrift Supervision v. Paul, 985 F. Supp. 1465, 1470 (S.D. Fla. 1997), a “district court cannot base the entry of summary judgment on the mere fact that the motion was unopposed but, rather, must consider the merits of the motion.” United States v. 5800 S.W. 74th Ave., 363 F.3d 1099, 1102 (11th Cir. 2004). II. Discussion Orlando Health seeks summary judgment on all eleven of HKS’s affirmative defenses, arguing that some are legally insufficient and that others

are unsupported by the evidence.2, And Orlando Health asserts that the Court is not precluded from entering summary judgment on all eleven affirmative defenses by HKS’s reservation of the right to assert additional affirmative defenses in its answer to the Amended Complaint. Orlando Health’s motion for

summary judgment is well taken because HKS asserts legally insufficient affirmative defenses and fails to show that its affirmative defenses are applicable. A. Failure to state a claim for third-party losses and consequential damages HK9’s first affirmative defense—that Orlando Health fails to state a claim for third-party losses and consequential damages—is legally insufficient. (Doc. 34 at 4). “Failure to state a claim is not an affirmative defense....” Havana Docks Corp. v. Carnival Corp., 592 F. Supp. 3d 1088, 1194 (S.D. Fla. 2022). B. Comparative fault of a nonparty HK9’s second affirmative defense asserts comparative fault of a nonparty. Orlando Health argues that HKS has not properly pleaded comparative fault or provided any evidence to support its applicability. But the Court need not reach

2 HKS’s affirmative defenses are: (1) failure to state a claim, (2) comparative fault, (8) setoff of collateral source payments, (4) first costs and betterment costs, (5) failure to mitigate damages, (6) economic waste, (7) chain of causation, (8) the doctrine under Slavin v. Kay, 108 So. 2d 462 (Fla. 1959), (9) the defense under Seibert v. Bayport Beach & Tennis Club Ass’n, 573 So. 2d 889 (Fla. 2d DCA 1991), (10) intervening and superseding acts, and (11) sufficiency of pleading delay damages. (Doc. 34 at 4-6).

these issues, because the defense is legally insufficient—“comparative fault is not a defense to a breach of contract claim.” Fed. Deposit Ins. Corp. v. Kunzmann Appraisals, Inc., No. 12-CV-80525, 2014 WL 12531543, at *3 (S.D. Fla. Feb. 11, 2014). C. Setoff of collateral source payments HKS’s third affirmative defense requests a setoff related to any collateral

source payments. This defense fails because HKS has not shown that the defense is applicable. There is no evidence that Orlando Health received “any amounts... from others arising out of or related to the same claims being alleged against HKS.” (Doc. 127 at 12-18). D. First costs and betterment costs, failure to mitigate damages, and economic waste HKS’s fourth, fifth, and sixth affirmative defenses relate to Orlando Health’s damages—specifically, first costs and betterment costs, failure to mitigate damages, and economic waste. HKS fails to present any evidence that shows that these affirmative defenses are applicable. The doctrine of first costs prevents a plaintiff “from obtaining damages that put it in a better place than it would have been if a contract was performed as agreed or if a tort never occurred.” AKCOM Tech. Servs., Inc. v. Pro. Servs. Indus., Inc., 580 F. Supp. 3d 1176, 1199 (M.D. Fla. 2021). Here, there is no evidence that Orlando Health’s claimed damages include first costs. And

,

Orlando Health submits that none of the damages it details in its affidavit include first costs.

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573 So. 2d 889 (District Court of Appeal of Florida, 1990)
Newberry Square Dev. Corp. v. Southern Landmark, Inc.
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Orlando Health, Inc. v. HKS Architects, Inc.; HKS Architects, Inc. v. BBM Structural Engineers, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/orlando-health-inc-v-hks-architects-inc-hks-architects-inc-v-bbm-flmd-2025.