Johnson Contractors, Inc. v. Starbelt, LLC, et al.

Summary

The United States District Court for the Northern District of Alabama addresses several summary-judgment motions in a construction-payment dispute arising from steel erection work on a Facebook data center. The court grants summary judgment to Starbelt and Meta on Johnson Contractors’ quantum meruit claims, denies Holder’s motion concerning fraud, and grants in part and denies in part Schuff’s motion concerning contract, delay-damages, waiver, and related issues. The opinion identifies the claims remaining for a February 2, 2026 bench trial.

Holdings

1. An express contract governing the subject matter of the services precludes a quantum meruit or unjust-enrichment claim even when the defendants seeking dismissal were not parties to that contract.
2. JCI could not avoid summary judgment on its quantum meruit claims for pre-work-order work because it presented no evidence that it reasonably expected Starbelt or Meta, rather than Holder, to compensate it.
3. Holder was not entitled to summary judgment because genuine disputes existed regarding whether Holder intentionally misrepresented that it would pay JCI directly and whether JCI suffered actual damages from the alleged misrepresentation.
4. Schuff was not entitled to summary judgment on its breach of contract counterclaim because it failed to establish its own performance under the subcontract or damages caused by JCI's alleged breach.
5. The express Schuff-JCI subcontract and Holder-JCI work order authorization barred JCI's quantum meruit claim against Schuff for services covered by those agreements.
6. Schuff was not entitled to summary judgment establishing that JCI's May 2022 lien-and-claims waiver released JCI's contract damages accruing before February 28, 2022, because the waiver did not name Schuff and was at least ambiguous as to contract claims.
7. Schuff was not entitled to summary judgment based on the no-damages-for-delay clause because a genuine dispute existed over whether JCI's claimed impact and productivity damages were actually delay damages covered by the clause.
8. JCI waived lost-productivity claims accruing before October 5, 2022, because it failed to provide the contractually required written notice within twenty-four hours and in the specified manner.

Questions Presented

1. Whether Starbelt and Meta were entitled to summary judgment on JCI's quantum meruit claims because express contracts governed the subject matter.
2. Whether JCI could pursue quantum meruit against Starbelt and Meta for pre-work-order acceleration work not covered by an express contract.
3. Whether Holder was entitled to summary judgment on JCI's fraudulent inducement claim for lack of evidence of intent to deceive or actual damages.
4. Whether Schuff was entitled to summary judgment on its breach of contract counterclaim based on JCI's failure to obtain prior written authorization before contracting with Holder.
5. Whether JCI's express contracts barred its quantum meruit claim against Schuff.
6. Whether a lien-and-claims waiver barred JCI's claims for damages accruing before February 28, 2022.
7. Whether the subcontract's no-damages-for-delay clause barred JCI's claimed delay, impact, acceleration, or productivity damages.
8. Whether JCI waived lost-productivity damages by failing to provide contractually required notice within twenty-four hours and in the specified manner.

Disposition

other