Scientific MacHine & Welding, Inc. v. FlashParking, Inc.

CourtCourt of Appeals of Texas
DecidedNovember 12, 2021
Docket03-20-00431-CV
StatusPublished

This text of Scientific MacHine & Welding, Inc. v. FlashParking, Inc. (Scientific MacHine & Welding, Inc. v. FlashParking, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Scientific MacHine & Welding, Inc. v. FlashParking, Inc., (Tex. Ct. App. 2021).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-20-00431-CV

Scientific Machine & Welding, Inc., Appellant

v.

FlashParking, Inc., Appellee

FROM THE 459TH DISTRICT COURT OF TRAVIS COUNTY NO. D-1-GN-19-003816, THE HONORABLE TIM SULAK, JUDGE PRESIDING

OPINION

Appellant Scientific Machine & Welding, Inc. sued appellee FlashParking, Inc. for

breach of contract, and alternatively, if no valid contract was found to exist, for recovery under

quantum meruit. FlashParking moved for summary judgment, arguing that Scientific had

repudiated the parties’ contract, that Scientific cannot recover under quantum meruit because the

parties had an express contract, and that there is no evidence of damages. The trial court granted

a take-nothing summary judgment disposing of all claims in favor of FlashParking. Because we

conclude that a valid contract existed between the parties and FlashParking established as a matter

of law that Scientific repudiated the parties’ express contract, we affirm.

BACKGROUND

Scientific is a manufacturing company that makes specialty machine parts.

FlashParking (formerly known as KleverLogic, Inc.) sells software and hardware to assist its

customers with parking solutions. In 2016, Scientific began manufacturing parking-payment kiosks (“SmartStations”) for FlashParking. Both FlashParking, as applicant, and Scientific, as

manufacturer, entered into separate contracts (the Applicant Contract and the Factory Contract,

respectively) with MET Laboratories, Inc. (“METLabs”) to certify the Underwriters Laboratories

(UL) compliance of the SmartStations.

UL compliance is a safety certification required for most electrical products, and

the evidence is undisputed that the SmartStations are unmarketable without the UL-compliance

mark. FlashParking’s expert attested that UL is a not-for-profit organization that sets safety

standards for different products, including information-technology equipment to be installed

outdoors. Certification of UL compliance requires a third-party inspector or auditor, such as

METLabs, to confirm that the product is manufactured and tested in a way that meets industry

safety standards. After METLabs authorized Scientific to apply the METLabs certification mark

denoting UL compliance (“MET Mark”) to FlashParking’s SmartStations in 2016, FlashParking

required all SmartStations to be UL compliant in both components and manufacturing process.

This contract dispute arose when FlashParking canceled its contract with Scientific in 2018,

asserting that Scientific had repudiated the contract by refusing to take the necessary steps to

maintain its certification to produce UL-compliant SmartStations.

Factual background

In 2016, FlashParking agreed to purchase 500 certified UL-compliant

SmartStations from Scientific in installments. That agreement was finalized and reduced to

writing in a document titled “Letter of Intent-Turnkey production of products,” which was

executed in January 2017. In connection with this agreement, FlashParking issued a purchase

order in December 2016 (“2016 Purchase Order”) for 500 SmartStations, in the amount of

2 approximately $1.5 million, with 250 to be delivered in three installments by April 2017 and the

remainder to be scheduled for delivery at a later time.

Scientific was authorized to apply the MET Mark to SmartStations, as long as

Scientific complied with the terms of the August 22, 2016 Factory Contract. 1 The 2016 Factory

Contract allowed METLabs to conduct unannounced inspections of Scientific’s factory and

required Scientific to comply with “very basic quality requirements” to allow METLabs the

capability to perform factory inspections. The 2016 Factory Contract further provided that

“[u]pon demand made by MET[Labs], the Factory shall immediately terminate application of the

MET Mark to any product(s) stipulated at any time by MET[Labs] to be ineligible.” (Emphasis

added.) When METLabs conducted an inspection of Scientific’s factory on August 31, 2017,

Scientific was found to be in compliance.

In early May 2018, Kevin Rose, one of Scientific’s employees, went to work for

FlashParking. FlashParking’s Vice President of Operations, Wes Vinecombe, attested that

Scientific’s president and sole shareholder, Alan Basta, became very angry when FlashParking

hired Rose. 2 Vinecombe further averred, and Scientific has not disputed, that Basta refused (1) to

deliver any additional SmartStations, including 165 SmartStations that were still owed and due

from the 2016 Purchase Order and that had already been completed and were awaiting delivery;

(2) to return the consigned parts that Scientific was holding, which belonged to FlashParking and

1 The 2016 Factory Contract provided for automatic renewal for periods of one year from the anniversary date, unless otherwise terminated for cause or if any party gave 30 days’ prior written notice of its intent to terminate. 2 Scientific sued Rose on August 29, 2018. The trial court granted Rose’s summary-

judgment motion, and Scientific has appealed that judgment to this Court in Cause No. 03-20-00564-CV. 3 were worth $360,000; and (3) to return the $84,465 that FlashParking had paid as a deposit on the

completed SmartStations—unless and until FlashParking fired Rose.

Vinecombe attested that when FlashParking refused to comply with Scientific’s

demand that it fire Rose, Basta stated that the only other way that Scientific would continue to do

business with FlashParking would be if FlashParking (1) placed an additional purchase order for

400 SmartStations at a cost of approximately $1.2 million and (2) paid Scientific an additional

$99,000 for the remaining 165 SmartStations that had not yet been delivered under the 2016

Purchase Order. 3 According to Vinecombe, Basta promised that this additional $99,000 would be

returned to FlashParking once they took delivery of the 400 units that he was requiring

FlashParking to buy. Vinecombe testified in his deposition that Basta’s withholding of inventory

was a “major business disruption” for FlashParking, causing it to have “no clear way to fulfill [its]

obligations” both to its investors and its customers. Vinecombe averred that FlashParking agreed

to the proposal because it had imminent deadlines to fill customer orders and no other source for

the SmartStations. On May 22, 2018, FlashParking issued a purchase order for an additional 400

SmartStations (“2018 Purchase Order”).

The 2018 Purchase Order required that all SmartStations be “UL compliant in both

components and manufacturing process.” The 2018 Purchase Order also provided that the 400

SmartStations would be delivered in installments, with the first installment of 100 units to be

delivered on October 15, 2018, and the balance to be delivered “subject to a release schedule.”

FlashParking began to take delivery of some of the 165 SmartStations that were already completed

under the 2016 Purchase Order, and it paid $49,200 of the $99,000 additional payment. On

3 This payment was described by FlashParking as a “duress premium” and by Scientific as a “Cancellation Credit.” 4 July 26, 2018, Scientific issued an invoice for the 50% deposit for the first 100 units that were to

be delivered on October 15, 2018. However, soon after the invoice was issued, FlashParking

received notice that Scientific had failed an unannounced July 25 inspection by METLabs of its

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

Related

Valence Operating Co. v. Dorsett
164 S.W.3d 656 (Texas Supreme Court, 2005)
In Re Kellogg Brown & Root, Inc.
166 S.W.3d 732 (Texas Supreme Court, 2005)
Lockhart Savings & Loan Ass'n v. RepublicBank Austin
720 S.W.2d 193 (Court of Appeals of Texas, 1986)
Truly v. Austin
744 S.W.2d 934 (Texas Supreme Court, 1988)
Plano Lincoln Mercury, Inc. v. Roberts
167 S.W.3d 616 (Court of Appeals of Texas, 2005)
Vortt Exploration Co., Inc. v. Chevron USA, Inc.
787 S.W.2d 942 (Texas Supreme Court, 1990)
Huckabee v. Time Warner Entertainment Co.
19 S.W.3d 413 (Texas Supreme Court, 2000)
Selectouch Corp. v. Perfect Starch, Inc.
111 S.W.3d 830 (Court of Appeals of Texas, 2003)
Provident Life & Accident Insurance Co. v. Knott
128 S.W.3d 211 (Texas Supreme Court, 2003)
Cook Composites, Inc. v. Westlake Styrene Corp.
15 S.W.3d 124 (Court of Appeals of Texas, 2000)
Taylor Publishing Co. v. Systems Marketing Inc.
686 S.W.2d 213 (Court of Appeals of Texas, 1984)
Group Life & Health Insurance Co. v. Turner
620 S.W.2d 670 (Court of Appeals of Texas, 1981)
New York Party Shuttle, LLC v. John Bilello
414 S.W.3d 206 (Court of Appeals of Texas, 2013)
Englehart v. Volunteer State Life Ins. Co.
195 S.W.2d 798 (Court of Appeals of Texas, 1946)
Usaa Texas Lloyds Company v. Gail Menchaca
545 S.W.3d 479 (Texas Supreme Court, 2018)
Albert G. Hill, Jr. v. Shamoun & Norman, Llp
544 S.W.3d 724 (Texas Supreme Court, 2018)
Omni USA, Inc. v. Parker-Hannifin Corp.
964 F. Supp. 2d 805 (S.D. Texas, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Scientific MacHine & Welding, Inc. v. FlashParking, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/scientific-machine-welding-inc-v-flashparking-inc-texapp-2021.