Travelers Property Casualty Co. v. Premier Project Management Group, L.L.C.

78 Va. Cir. 315, 2009 Va. Cir. LEXIS 162
CourtHanover County Circuit Court
DecidedMay 7, 2009
DocketCase No. CL08000728-00
StatusPublished

This text of 78 Va. Cir. 315 (Travelers Property Casualty Co. v. Premier Project Management Group, L.L.C.) is published on Counsel Stack Legal Research, covering Hanover County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Travelers Property Casualty Co. v. Premier Project Management Group, L.L.C., 78 Va. Cir. 315, 2009 Va. Cir. LEXIS 162 (Va. Super. Ct. 2009).

Opinion

By Judge J. Overton Harris

Before the Court are the demurrers of fifteen third-party defendants to the Third-Party Complaint of Defendant Premier Project Management Group, L.L.C. (PPMG). Four additional third-party defendants have not answered the Third-Party Complaint or otherwise appeared in this case. The Court heard arguments on the demurrers on March 27, 2009, and took the matter under advisement. Upon thorough review of the pleadings and the law, the Court finds as follows.

[316]*316I. Background

On February 2,2006, the Covenant Woods retirement complex was the site of a massive and destructive fire. The inferno resulted in a significant loss of housing for the elderly and millions of dollars in damages. Upon investigation, the cause of the fire was determined to be an ignited pile of trash on the balcony of a building then under construction. No determination has ever been made as to whose trash constituted the pile or who may have caused the trash to catch fire.

The damage caused by the fire was borne financially by Travelers Property Casualty Company of America (Travelers), the property insurer for Covenant Woods. Travelers subsequently filed this suit, seeking indemnification due to alleged negligence and breach of contract on the part of PPMG, the property managers Covenant Woods contracted to oversee the site.

PPMG then filed its Third-Party Complaint against nineteen defendants. The first count of the Third-Party Complaint is asserted against one defendant, The Flaskell Group of Florida (Haskell). Haskell was the general contractor in charge of the construction that was underway at the time of the fire. Count I alleges that PPMG has a right to contribution and contractual indemnity based on Haskell’s own contract with Covenant Woods, a contract to which PPMG was not a party.

Count II is lodged against the remaining defendants, all of whom allegedly had employees present on the Covenant Woods worksite prior to the fire. The claimed causes of action against these defendants are common law contribution and indemnity, based on the theory that each defendant had a common law duty not to negligently accumulate flammable trash and allow it to catch fire.

II. Standard of Review

A demurrer may be employed to strike a pleading that does not state a cause of action or fails to state facts upon which relief may be granted. Code of V irginia §8.01-273.A demurrer admits the factual pleadings to be true and accepts any reasonable factual inferences fairly and justly drawn from them. Fox v. Custis, 236 Va. 69, 71, 372 S.E.2d 373, 374 (1988). The demurrer does not, however, admit the correctness of the pleading’s conclusions of law. Id.

III. Count I

[317]*317PPMG’s allegation in Count I is based on a clause in Haskell’s contract which states:

To the greatest extent permitted by law, Contractor shall indemnify and hold harmless Owner, its employees, agents, and other contractors from and against all damages, losses, expenses, claims, or liabilities... incurred by or asserted against Owner ... for loss of or damage to property... to the extent arising out of the Contract or the performance of the Work....

Haskell’s contract also states:

Contractor at all times shall keep the Site free from accumulation of excess waste materials or rubbish caused by or resulting from the Work. . ..

PPMG claims that it is an “agent” or “other contractor” as contemplated in Haskell’s contract and that Haskell’s alleged failure to keep the Site free of “excess waste materials” breached its duty under the contract. PPMG’s claim is under the “third-party beneficiary doctrine,” which states that a party not in privity to a contract may maintain an action under that contract if a promise is made, in whole or in part, for its benefit. Code of Virginia § 55-22.

Haskell counters that its contract with Covenant Woods has yet another, more controlling clause:

The Contract is intended to be solely for the benefit of Owner and Contractor and their successors and permitted assignees and is not intended to and shall not confer any rights or benefits on any third party. .. not a signatory hereto.

In Richmond Shopping Center v. Wiley N. Jackson Co., 220 Va. 135, 255 S.E.2d 518 (1979), the Supreme Court of Virginia faced the same issue. A third party sought a cause of action under a contract that contained a provision specifically excluding rights and benefits to parties to the contract. Richmond Shopping Center, 220 Va. at 142-43. The Court found that it would be improper to attempt to discern third-party benefits from other parts of the contract where unambiguous terms had already specifically dealt with and disposed of them. Id. at 143.

As in Richmond Shopping Center, this Court need not look elsewhere in the contract, nor beyond its four comers, to determine the clear intent [318]*318manifested by the parties thereto. Id. at 142. Covenant Woods and Haskell unambiguously expressed their intention to deny third parties any rights or benefits under the contract. The contract provides PPMG no cause of action, and Haskell’s demurrer is thus sustained.

IV. Count II

The remaining third-party defendants claim three reasons why PPMG has failed to plead a cause of action against them. The first is the economic loss rule, whereby a party not in privity with a defendant cannot recover for a purely economic loss. The second is that contribution is disallowed because Covenant Woods itself has no cause of action against the third-party defendants. The third is that equitable indemnification is disallowed because there has been no initial finding that the negligence of any of the defendants caused the damages.

A. Economic Loss Rule

The economic loss rule stands for the proposition that where there is no privity between the parties and a claimed loss is purely economic, the only remedy is in contract. Sensenbrenner v. Rust, 236 Va. 419, 425, 374 S.E.2d 55, 58 (1988); Blake Construction Co. v. Alley, 233 Va. 31, 34-35, 353 S.E.2d 724, 726 (1987). If PPMG claimed that the defendants caused bodily harm or damaged PPMG property, a cause of action in tort could lie. Blake, 233 Va. at 34-35. In a claim for purely economic damages, however, no duty of care or skill may be imposed absent a contract, and so there is no tort cause of action. Id.

PPMG’s count against the remaining third-party defendants is clearly a tort claim based upon an alleged breach of an alleged duty of care. Its claim of damages is nothing more than the money Travelers seeks as indemnification from PPMG, a purely economic loss. The demurrers of the remaining third-party defendants are thus sustained due to the economic loss rule.

B. Contribution

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Related

Carr v. Home Insurance
463 S.E.2d 457 (Supreme Court of Virginia, 1995)
Fox v. Custis
372 S.E.2d 373 (Supreme Court of Virginia, 1988)
Richmond Shopping Center, Inc. v. Wiley N. Jackson Co.
255 S.E.2d 518 (Supreme Court of Virginia, 1979)
Virginia Electric & Power Co. v. Wilson
277 S.E.2d 149 (Supreme Court of Virginia, 1981)
Blue Cross v. McDevitt & Street Co.
360 S.E.2d 825 (Supreme Court of Virginia, 1987)
Blake Const. Co., Inc. v. Alley
353 S.E.2d 724 (Supreme Court of Virginia, 1987)
Sensenbrenner v. Rust, Orling & Neale, Architects, Inc.
374 S.E.2d 55 (Supreme Court of Virginia, 1988)
Walker v. Vanderpool
302 S.E.2d 669 (Supreme Court of Virginia, 1983)
Thweatt's Administrator v. Jones
1 Rand. 328 (Supreme Court of Virginia, 1823)

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Bluebook (online)
78 Va. Cir. 315, 2009 Va. Cir. LEXIS 162, Counsel Stack Legal Research, https://law.counselstack.com/opinion/travelers-property-casualty-co-v-premier-project-management-group-llc-vacchanover-2009.