Wiley & Wilson, Inc. d/b/a Wiley|Wilson v. Pontiac Drywall Systems, Inc. d/b/a PDSI Contractors

Summary

The United States District Court for the District of Maryland denied Wiley & Wilson, Inc.’s motion for summary judgment in a dispute arising from architectural and design services for a U.S. Naval Academy renovation project. The court held that genuine disputes existed regarding whether Pontiac Drywall Systems properly withheld payment as recoupment for alleged delay-related damages. The court also held that expert testimony was not required to establish the alleged breach based on failure to meet contractual project deadlines.

Holdings

1. Summary judgment was inappropriate because the record presented a genuine dispute over whether PDSI withheld payment as a prohibited penalty or instead to recoup losses allegedly caused by Wiley & Wilson’s contractual delays.
2. Wiley & Wilson was not entitled to summary judgment on its alternative quantum-meruit or unjust-enrichment claim because the record did not establish as a matter of law that PDSI’s withholding of payment was unlawful or inequitable.
3. Wiley & Wilson was not entitled to summary judgment merely because PDSI had not designated a qualified design professional to testify about the professional standard of care; PDSI’s counterclaim also alleged breach based on failure to meet the contractual schedule.

Questions Presented

1. Whether Wiley & Wilson was entitled to summary judgment on its breach-of-contract claim based on PDSI’s withholding of payment.
2. Whether Wiley & Wilson was entitled to summary judgment on its alternative quantum-meruit or unjust-enrichment claim.
3. Whether PDSI could establish breach of the contract’s professional-standard-of-care provisions without expert testimony from a qualified design professional.
4. Whether PDSI’s counterclaim could proceed on the independent theory that Wiley & Wilson breached the contractual schedule by performing late.

Disposition

other