Pritchard Industries, Inc. v. Eatontown Board of Education

CourtNew Jersey Superior Court Appellate Division
DecidedMarch 21, 2024
DocketA-1834-22
StatusUnpublished

This text of Pritchard Industries, Inc. v. Eatontown Board of Education (Pritchard Industries, Inc. v. Eatontown Board of Education) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pritchard Industries, Inc. v. Eatontown Board of Education, (N.J. Ct. App. 2024).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-1834-22

PRITCHARD INDUSTRIES, INC.,

Plaintiff-Appellant,

v.

EATONTOWN BOARD OF EDUCATION,

Defendant-Respondent.

Submitted February 26, 2024 – Decided March 21, 2024

Before Judges Sabatino and Marczyk.

On appeal from the Superior Court of New Jersey, Law Division, Monmouth County, Docket No. L-3648-20.

Skoloff & Wolfe, PC, attorneys for appellant (Patrick T. Collins, on the briefs).

Collins, Vella and Casello, attorneys for respondent (Dennis Anthony Collins, on the brief).

PER CURIAM This litigation stems from the nonpayment of money that defendant

Eatontown Board of Education (the "School Board") allegedly owed to a

custodial services contractor, plaintiff Pritchard Industries, Inc. ("Pritchard").

The School Board asserts Pritchard failed to meet minimum staffing

requirements and improperly billed the School Board for hours that staff had not

worked.

The trial court granted summary judgment to the School Board, dismissing

Pritchard's claim to recover $92,297.30 for staff hours not worked. Pritchard

now appeals, contending the court misinterpreted the terms of the contract

between the parties. It asserts the School Board received the benefit of its

contractual bargain because the school facilities were indisputably cleaned on

the short-staffed days. Pritchard further contends the School Board's sole

remedy under the contract is a $50 penalty per employee per shift, which has

already been withheld by the School Board. In the alternative, Pritchard argues

the trial court's award unjustly enriches the School Board.

For the reasons that follow, we vacate the entry of summary judgment and

remand for a trial or evidentiary hearing. The trial or hearing shall ascertain the

probable intent of the parties concerning the monetary consequences of

Pritchard's failure to supply the promised number of custodians on various days

A-1834-22 2 during the contract period, and, in particular, whether the $50 penalty was

intended to serve as an exclusive remedy for short-staffed days.

I.

Because we are remanding for further development of the record and

additional findings, we need not recite the facts definitively or comprehensively.

The following summary will suffice for present purposes.

After competitive bidding under the Public Schools Contracts Law,

N.J.S.A. 18A:18A-1 to -68, Pritchard was awarded a contract to serve as the

School Board's custodial services provider for a two-year period from July 1,

2016 through June 30, 2018.

Both parties agree Pritchard adequately cleaned the schools during the

contract period. However, on certain dates Pritchard did not provide, on site,

the number of custodians specified in the contract. Consequently, the School

Board withheld $92,297.30 in custodian wages that Pritchard had charged the

School Board for employees who were absent on those dates.

The School Board argues the contract entitles it to withhold such funds,

and to also assess a $50 penalty per shift when Pritchard failed to provide enough

custodial staff to meet "minimum staffing requirements" specified in the

contract. Pritchard concedes that the $50 penalty was properly imposed, but it

A-1834-22 3 appeals the trial court's finding that the School Board was also entitled to deduct

the wages of absent employees.

Pritchard contends the $50 penalty is a liquidated damages provision that

was intended to be the exclusive remedy for any failure to deploy enough

custodians. Pritchard maintains the trial court should not have made a better

contract for the School Board than the one that was bid and awarded.

The School Board, in turn, argues that the $50 penalty was not an

exclusive remedy, and that it was also entitled to withhold employee wages for

unfilled shifts when Pritchard did not furnish the promised number of

custodians.

The key contractual provisions germane to this dispute are set forth in the

bid documents and the parties' ensuing signed agreement. The following

provisions from the bid documents are particularly relevant:

Employees' Salaries and Fringe Benefits. In the proposal, bidder must state proposed wage rates for Evening/Second Shift Manager/Supervisor, custodial and maintenance staff. The Contractor will establish the Terms and Conditions under which any employees will be hired. The Contractor will have the sole responsibility to compensate its employees including all applicable taxes, insurances and Workers Compensation.

All Contractor employees will comply with all rules of the District. Employees of the Contractor must be

A-1834-22 4 thoroughly trained, qualified and capable of performing the work assigned to them. Employees of the Contractor must be capable of both understanding and speaking English in order to take direction from appropriate District personnel in the event of an emergency or under circumstances where immediate action is necessary to protect persons or property. Employees of the Contractor will not socialize with any students of the District. All penalties shall be deducted from the contract amount due upon written notification to the Contractor for any week(s) that the minimum staffing levels have not been met.

[(Emphasis added).]

The underscored last sentence of the above provision, referring to

"penalties," corresponds to the $50 "penalty" referred to in the following section

of the bid documents concerning absent employees:

Employee Absences and Penalties. The Contractor must anticipate employee absences and provide the district with an adequate backup plan for loss of work time associated with terminations, sick time and vacation. It is the expectation of the School District that the minimum staff levels will be maintained each night during the school year. Therefore an adequate supply of substitutes or coverage must be kept in order to ensure full coverage during the school year. Any time the Contractor does not provide full minimum staffing during the life of the contract, the District has the option to penalize the Contractor. The calculation shall be confirmed by reviewing detailed payroll reports, which must be provided by the Contractor monthly. The District may assess a penalty of $50.00 per employee per day for less than full minimum staffing. All penalties shall be deducted from the

A-1834-22 5 contract amount due upon written notification to the Contractor for any week(s) that the minimum staffing levels have not been met. All employees of the Contractor must punch a time card daily, including the Evening/Second Shift Manager/Supervisor.

Additionally, the bid documents address the grounds and procedures

enabling the School Board to terminate the contract, and specify the damages

that the contractor might owe the School Board upon breaching the contract:

41. Termination of Contract.

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Pritchard Industries, Inc. v. Eatontown Board of Education, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pritchard-industries-inc-v-eatontown-board-of-education-njsuperctappdiv-2024.