Pickens v. Cunningham

22 Pa. D. & C.3d 40, 1981 Pa. Dist. & Cnty. Dec. LEXIS 188
CourtPennsylvania Court of Common Pleas, Mercer County
DecidedSeptember 21, 1981
Docketno. 711 C.D. 1980
StatusPublished

This text of 22 Pa. D. & C.3d 40 (Pickens v. Cunningham) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Mercer County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pickens v. Cunningham, 22 Pa. D. & C.3d 40, 1981 Pa. Dist. & Cnty. Dec. LEXIS 188 (Pa. Super. Ct. 1981).

Opinion

ACKER, J.,

This matter comes before the court upon an order for reargument upon preliminary objections of defendant to plaintiff’s complaint in assumpsit. This court en[41]*41tered an order upon the preliminary objections previously reserving decision concerning proper measure of damages for a pre-trial conference. The attorneys desire, however, to have a determination of the measure of damages prior to a pre-trial conference. Hence, this court granted the request for reargument. To assist in the determination of the issue of the proper measure of damages, certain exhibits have been received by the court. Exhibit “B” is the plan referred to in the contract for the construction of the building. The latter is captioned Exhibit “A” and is attached to the complaint. Plaintiff contends that the residence as actually constructed is 109.5 square feet smaller than the dimensions of the house contracted for; that the garage, living room, bathroom and bedroom are undersized, as compared to the size as shown on defendant’s blueprint drawing; that there is no half-bath as shown on the blueprint drawing; that there are no glass panels beside the front door as shown on the blueprint drawing; and that the garage door is undersized. The contract for construction of the residence called for a total contract price of $43,900. In order to correct the claimed errors as set forth above, plaintiff desires damages of $35,200. In addition, plaintiff claims damages due to seepage in the basement and other work which is claimed was done in an unworkmanlike manner which brings the total claim of plaintiff to $45,368. This is, of course, in excess of the entire contract price.

The applicable contract language provides, “Home to be built according to prints designed by Contractor. Size of Dwelling Approximately 26'8" x 69' x 32'6" x 36' including garage. House consists of kitchen, dining room, rec. room, living room, three bedrooms, bath and a half.”

[42]*42By Exhibit “D”, which is an estimate and contract of Robert J. Foltz, General Contractor, supplied to plaintiff, the basic problem is described by comparing the construction blueprint outside dimension of 32'6" to the dimensions required to accommodate the room size as set forth in the drawing produced by defendant. To do so the foundation should have been outside to outside 36'8". By measurement it is claimed to be 33'8". Due to this error, according to Foltz, the house is short 109-V2 square feet and did not contain a half bath. Folz conjectures in his report that the contractor had to realize there was an error when he laid out the building on the ground before the basement was dug. Establishment of that conclusion at trial may well expand the measure of damages for plaintiff as noted hereafter. Defendant addresses two questions which are here discussed.

I. If There is an Inconsistency Between the Contract and the Blueprints as to the Width of the House Which Prevails?

Plaintiff does not regard that there is any inconsistency between the contract and the plan. To take that view is somewhat an over-simplification for although the contract provides that the wall in issue, being the north wall, is to be 32'6" and the plan shows it to be 32'6", when the room size of the various rooms making up the residence are considered by totaling their length, it is seen that the north wall foundation would have to be 36'8". Although the actual outside wall as constructed is 33'8", being 1'2" over the blueprint, it is 3' short of what was required to meet the dimensions of the rooms comprising the house as set forth in the same sketch or plan prepared by defendant-contractor.

[43]*43The case law in Pennsylvania, although sparse, appears to follow a general rule that a contractor who builds according to his own plans should be liable for the defects in his work: Filbert v. Philadelphia, 181 Pa. 530, 37 Atl. 545 (1897); Canuso v. Philadelphia, 326 Pa. 302, 192 Atl. 133 (1937); and Miller v. Homeopathic Hospital, 243 Pa. 502, 90 Atl. 394 (1914).

At least as to other jurisdictions than Pennsylvania, the general rule would appear to be that a contract prevails over the specifications or plans where there is a conflict: Barraque v. Neff, 202 La. 360, 11 So. 2d 697 (1942). In McConnell v. Gordon Construction Co., 105 Wash. 659, 178 P. 823 (1919), it was held that if either party to a building contract agrees to furnish and does furnish the plans for the building, he thereby guarantees their sufficiency for the purpose.

In Jim Mahoney, Inc., v. Galokee Corporation, 214 Kan. 754, 522 P. 2d 428 (1974), the building contract incorporated the plans, drawings and specifications by reference. The written contract provided that the parking lot would have a gravel base. A Schematic drawing indicated that the driveways and parking lot would be covered with asphalt. It was held that the specification served the purpose of explaining and amplifying but not adding to the provisions of the contract. In Brown-Randolph Co. v. Gude, 151 Ga. 281, 106 S.E. 161 (1921), it was held that where a conflict exists between a building contract and the specifications that the former prevails. For the same effect, see Gardner v. City of Englewood, 131 Colo. 210, 282 P. 2d 1084 (1955) and McGarry Contracting Co. v. Board of Education of City of New York, 284 N.Y. 218, 30 N.E. 2d 482 (1940); Warren v. Gray, 90 Ga. App. 398, 83 S.E. 2d 86 (1954).

[44]*44It is defendant’s position that the contract called for a north wall of 32'6" in length and the drawing of defendant shows that wall being 32'6" in length. Therefore, plaintiff got what she contracted for. Plaintiff’s contention is that if you add the dimensions of the various rooms comprising the north wall, it is readily apparent there was insufficient area but in addition even if the contract has been fulfilled as to dimensions by taking defendant’s position at the best the half bath as provided in the drawings was left out due to lack of space. Defendant relies on Cek v. Karinch, 11 Lebanon 371 (1967). In that case, plaintiff had contracted with defendant for construction of a dwelling. The contract incorporated by reference a set of specifications and a set of blueprints both prepared by defendant. The furnished home met the requirements of the blueprints but not the specifications. The court made a distinction between blueprints or plans and specifications, pointing out that the plans are to illustrate or explain the work which is to be done while the specifications are to provide the kind, quality and quantity of work to be done. The details meant the time and manner of construction without which the contract would be incomplete and ineffective. This case is inapplicable for in the instant case there were no specifications separate from the contract nor could plaintiff determine any of the details as to how her house was laid out or the size of the rooms without the plan which was specifically referred to and incorporated into the contract. Only by reading the plans can the owner gain a concept of how large each room is to be as well as the layout and location of the rooms in relation to each other.

Wherefore, we believe Cek v. Karinch to be inapposite. It is true that normally plans are not in the [45]*45same sense or to the same extent to be considered an integral part of the contract as are the specifications: Hartley-Zeigler v. Bacon, 251 Pa. 87, 96 Atl. 257 (1915).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Warren v. Gray
83 S.E.2d 86 (Court of Appeals of Georgia, 1954)
Gardner v. City of Englewood
282 P.2d 1084 (Supreme Court of Colorado, 1955)
Mahoney, Inc. v. Galokee Corporation
522 P.2d 428 (Supreme Court of Kansas, 1974)
Edwin J. Schoettle Co. Appeal
134 A.2d 908 (Supreme Court of Pennsylvania, 1957)
Bloomsburg Mills, Inc. v. Sordoni Construction Co.
164 A.2d 201 (Supreme Court of Pennsylvania, 1960)
Heidt v. Aughenbaugh Coal Co.
176 A.2d 400 (Supreme Court of Pennsylvania, 1962)
Brourman v. Bova
182 A.2d 245 (Superior Court of Pennsylvania, 1962)
Kennedy v. ERKMAN
133 A.2d 550 (Supreme Court of Pennsylvania, 1957)
Robert F. Felte, Inc. v. White
302 A.2d 347 (Supreme Court of Pennsylvania, 1973)
Barraque v. Neff
11 So. 2d 697 (Supreme Court of Louisiana, 1942)
McGarry Contracting Co. v. Board of Education of New York
30 N.E.2d 482 (New York Court of Appeals, 1940)
Canuso v. Philadelphia
192 A. 133 (Supreme Court of Pennsylvania, 1937)
McConnell v. Gordon Construction Co.
178 P. 823 (Washington Supreme Court, 1919)
Brown-Randolph Co. v. Gude
106 S.E. 161 (Supreme Court of Georgia, 1921)
Filbert v. City of Philadelphia
37 A. 545 (Supreme Court of Pennsylvania, 1897)
Pressy v. McCornack
84 A. 427 (Supreme Court of Pennsylvania, 1912)
Smith v. Cunningham Piano Co.
86 A. 1067 (Supreme Court of Pennsylvania, 1913)
Hartley-Zeigler Co. v. Bacon
96 A. 257 (Supreme Court of Pennsylvania, 1915)
Parkes v. Opfermann
119 A.2d 624 (Superior Court of Pennsylvania, 1956)

Cite This Page — Counsel Stack

Bluebook (online)
22 Pa. D. & C.3d 40, 1981 Pa. Dist. & Cnty. Dec. LEXIS 188, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pickens-v-cunningham-pactcomplmercer-1981.