April 7, 2016

The Life and Death of a Roof: A condominium building with a low-slope roof (commonly but incorrectly referred to as a “flat” roof) will need a reroof every seven to twenty years. This is a major budget item that can cost from $8 to $15 per square foot of roof deck, which quickly adds up to hundreds of thousands of dollars on a typical Florida condominium building. Roofing is one of the largest investments a condominium association will ever make. If the results are a faulty roof, the decisions made can quickly become the biggest source of grief a condominium board will ever face.

Your Warranty – Will Anyone Answer the Phone? One benefit of a reroof project is the warranty from the manufacturer and roof installer. But manufacturer’s roof warranties (and often, other vendor contracts) contain unpleasant fine print surprises. All warranties are not created equal, and an effective Board must look far into the details of the warranty document, far beyond the number of years promised, and who is making what promises. When shopping for roofing contractors you will hear flowery terms like “master contractor” and “elite contractor,” or “non-prorated warranty pledge” and “lifetime warranty.” None of these marketing terms mean anything if something goes wrong with your expensive new roof. All that will matter is the legal language in the contract and warranty.

The legal entities that are the roofing installer’s corporation or LLC can be (and often are) quickly dissolved and reformed at the convenience of the roofer, resetting their past liabilities to zero. For this reason and many others, a roofing installer’s warranty is typically not as valuable as the roofing manufacturer’s warranty.

The Fine Print May Be Where The Money Is:   One of those surprises could require your association to hire a lawyer in Pennsylvania, or go before a judge and jury in Michigan, to enforce the warranty to pay for a roof leak in your Florida building. Chasing a roofing contractor or manufacturer back to their home state for a lawsuit after they fail to meet warranty obligations can be prohibitively expensive. Many major roofing contractors and manufacturers include clauses in their warranties that would require your Florida association to bring any lawsuit to enforce the warranty in the manufacturer’s home state. One author of this article has recently testified as an expert witness in a lawsuit brought by a Florida condominium over a roof warranty dispute. The association was forced to hire a lawyer in Pennsylvania to prosecute the case in the manufacturer’s home county in Pennsylvania. Hiring a second and remote lawyer necessarily costs the association a great deal more money. Many lawyers would agree that a Florida condominium association suing a manufacturer in its home town may face a further problem of jury bias in favor of the “home town” company.

Conversely, the association would have greater negotiating leverage if the manufacturer faced the costs of hiring a Florida lawyer to defend its product before a Florida jury from the association’s home county. The manner in which the litigation venue is typically specified by the roofing companies is no accident.

It’s important for the association, when signing any contract with a vendor or service provider, to carefully read all of the vendor’s contract. The “fine print” or “boilerplate” (usually the final few paragraphs or back side of the contract) contain clauses that shift the advantage to the vendor if there’s a dispute about performance or a lawsuit. The co-author’s lawsuit involved a clause that read:

“Any disputes or actions relating to or arising out of the work to be performed pursuant to this Sales Agreement shall be exclusively governed by the laws of the Commonwealth of Pennsylvania. Jurisdiction and venue of any action proceeding out of relating to the Agreement shall be vested in the courts in Washington County, Pennsylvania. (e.s.) Purchaser irrevocably waives any objections it now has or may hereafter have to the convenience or propriety of this venue….. To be valid, any changes to the Warranty must specifically approved in by Corporate Officer of manufacturer”

Florida courts will enforce these “venue clauses” and “choice of law clauses”. Usually, paying a lawyer to challenge such a clause is money wasted. The time for the association to win the venue fight is before the contract is signed. The association’s representative should read all bids and contracts with care to make sure it doesn’t contain references to “venue,” “actions,” or “jurisdiction” in other states, or refer to the law of a state other than Florida.

The bigger picture is that a contract that is difficult or costly to enforce is a ghost of a contract. If a vendor makes it too expensive to legally enforce a contract, it can walk away from the promise and get away with it. (Economists and lawyers call this “transaction cost,” and transaction costs are one of the biggest overlooked issues in legal disputes. In simplest terms, let’s not spend a dollar to recoup fifty cents. Venue clauses are designed to make the buyer spend a dollar to recover the fifty cents.)

Suggestions For The Battle Of The Fine Print:

  1. Cross Out The Language And Have The Change Initialed. Buyers shouldn’t hesitate to strike out unacceptable language in a contract before the salesman closes the sale. This is when you have the negotiating leverage — not after a roof or other problem manifests. We mean, literally, take a pen and strike through the language, so it looks like this:

Any disputes or actions relating to or arising out of the work to be performed pursuant to this Sales Agreement shall be exclusively governed by the laws of the Commonwealth of Pennsylvania. Jurisdiction and venue of any action proceeding out of relating to the Agreement shall be vested in the or courts in Washington County, Pennsylvania. Purchaser irrevocably waives any objections it now has or may hereafter have to the convenience or propriety of this venue….. To be valid, any changes to the Warranty must specifically approved in by Corporate Officer of manufacturer[YOUR INITIALS][SELLER’S INTIALS][MANUFACTURER’S INITIALS]

This may or may not work. The salesman may protest, pretend to walk away, or really walk away and take his company out of the game. This suggestion applies to any contract — from a reroof to buying bottled water to lawn service. As with most negotiations, the party who needs the deal more typically backs down. If your association has asked for competitive bids for the project — as suggested below — it should have a few vendors to choose from. This should give your association leverage.

The manufacturer whose clause we quote above anticipates this move by requiring any warranty changes to be approved by a “corporate officer.” The association would need to secure the signature of the manufacturer’s corporate officer to make the strikethrough and deletion stick.

  1. Competitive Proposals. A major project (such as a reroof, a balcony restoration, or a cathodic protection system) should start with an invitation to competitive bids, in writing, with written specifications prepared by a design professional. The invitation to bid and specifications can contain your own version of the venue and choice of law provision, and other useful legal tools beyond the scope of this article. These may conflict with language in the vendor’s boilerplate. However, the courts will typically hold that language created for a specific transaction will control over general “boilerplate” used by the seller for all its transactions.

It’s important to remember the roofing installer and the roof material manufacturer are two different legal entities. The contract between the association and the roofing contractor may not necessarily be legally binding on the materials manufacturer. In fact, without careful draftsmanship, it probably won’t be.

A warranty is only as good as the ability of the vendor it to stay in business, provide the repairs, or pay claims. This is one reason the manufacturer’s warranty has value. A local roofer may go out of business or lack the money to pay a judgment; the manufacturer is likely to have a deeper pocket.

Like two parachutes, two warranties are better than one. The goal should be to have both the installer and the manufacturer provide separate warranties.

Andrew Showen is a board certified construction lawyer with Hill Rugh Keller & Main, Orlando, Florida, 407-926-7460 (andy@hrkmlaw.com). Sean Burlingham, P.E., 321-693-2049 (sean@strongbuilding.com) is an engineer practicing in Brevard County and across the state of Florida with expertise in concrete buildings and condominiums. This article is not legal or engineering advice and does not create a client relationship.

HRKM News

06/20/2023

Board-Certified Construction Lawyer Andrew Showen spoke at NASTT

Board certified construction lawyer Andrew Showen of Hill Rugh Keller & Main spoke at the North American Society for Trenchless Technology (NASTT) annual convention in Portland, Oregon in May 2023.  Andy discussed the results of a Manatee County

10/03/2022

State Of Florida Starts Receivership Proceedings Against Fednat Insurance Company

On September 23, 2022, the Florida Department of Insurance filed a petition to place FedNat Insurance Co. in receivership. The petition alleges that FedNat acknowledged in September 2022 that it did not have enough cash on hand to meet its current ob

09/01/2022

Florida Special Legislative Session Amendment To Building Code “25% Rule” Impacts Roofers, Homeowners And Insurers

Building owners needing repairs on a portion of their building are often chagrined to discover that they must pay for an entirely new assembly, because of the “25% rule”.  This was a requirement in the Florida Building Code (2017 Florida Buildin

02/09/2021

Florida Court Holds HDD Is Not An Abnormally Dangerous Activity; Alleged Damage to Bridge 90 Feet From HDD Bore Held Not Foreseeable As A Matter of Law

A Florida circuit court has rejected a claim by a property owner that HDD is an abnormally dangerous activity, and that the HDD contractor cannot be subjected to strict liability for damage alleged to bridge. In an earlier ruling, the court held th

04/03/2020

Beginning April 1, FFCRA Requires Employers Of 500 Persons Or Less To Provide Paid Medical Leave To Certain Employees Affected By Covid-19 — But Only If The Employee Can’t “Telework”

The Families First Coronavirus Response Act (“FFCRA”) was passed by Congress and signed by the President on March 18, 2020.  (The law in question is technically titled “Emergency Paid Sick Leave Act” see H.R. 6201 §5101.  We’ll call

03/17/2020

Florida Department of Economic Opportunity Is Pushing Out Emergency Bridge Loans to Small Business at 0% Interest For One Year

To assist small businesses to stay open and pay employees during the COVID-19 slowdown, Governor DeSantis has authorized the Florida Department of Economic Opportunity to extend 0% interest emergency bridge loans to small businesses.  The loans ar

01/10/2020

HRKM Wins Directed Verdict in Auto Repair Professional Liability Case

An often overlooked consideration during most initial case evaluations, is the applicability of the Statute of Limitations. A prime purpose of the statute of limitations  is to protect defendants from facing surprise and stale claims which positio

07/24/2019

HRKM Collaborates with ABC Student Chapter

Hill, Rugh, Keller & Main is proud to be a member of the largest commercial construction trade association, Associated Builders and Contractors (ABC), Central Florida Chapter. According to ABC’s website, “the Central Florida Chapter of ABC i

07/08/2019

Statute of Limitations for Roof Defect Claim Runs from Time of Notice of Roof Leak Not Knowledge of the Specific Defect

The Third District Court of Appeal in Covenant Baptist Church, Inc. v. Vasallo Construction, Inc. in an opinion filed on May 22, 2019, held that an owner was barred by the statute of limitations from filing a lawsuit for a defective roof when th

03/12/2019

Proposed amendment to ch. 558 would require nonbinding arbitration and allocation of damages to “own work”

During the first week of March, a bill (SB 1246/HB911) to modify the chapter 558 process by adding nonbinding arbitration was filed in the Florida House.  Proposed Sec. 558.045 would require nonbinding arbitration in any construction defect lawsuit

10/17/2018

The Repose That Wasn’t: Florida Extends The Statute of Repose For Construction Claims By A Year (Or Maybe More)

Folklore in the construction business is that you can safely throw out your records after seven years because the IRS will only chase you for that long.  Effective July 1, 2018, people in the business need to basically double that period, because o

03/01/2018

Protecting Your Business Domain Begins When You Select It

Check out the link below to read HRKM Owner and Partner, Chris Hill’s, Forbes magazine article. https://www.forbes.com/sites/groupthink/2018/02/25/protecting-your-business-domain-begins-when-you-select-it/#3c6da553130e

01/31/2018

Former Congressman Ric Keller’s T.V. Commentary on President Trump’s SOTU Address

Check out Former Congressman Ric Keller’s T.V. commentary on President Trump’s State of the Union Address (see at 1 min.) https://www.fox35orlando.com/politics/310093012-video

06/26/2017

Defending Class Action Lawsuits

Have you been served with a Telephone Consumer Protection Act (“TCPA”) class action? If so, several questions come to mind: What is the TCPA? Why am I being sued? How do I make this TCPA lawsuit go away without destroying my business? By

06/06/2017

Defending Property Owners When Serious Construction Accidents Happen

Has a construction worker been injured while working on your property?  If so, several questions come to mind: Will I be sued? Do I have enough insurance? Could the millions of dollars sought by plaintiffs’ attorneys for alleged wrongful death or

05/17/2017

Is There Still A Right To Setoff Settlement Amounts Paid By A Co-Defendant In A Negligence Case Involving Multiple Defendants

Florida Statute § 768.81, titled “Comparative Fault”, provides a statutory scheme for determining damages in a “negligence action” and apportioning these damages if there are multiple parties involved.  The statute expressly defines a

04/17/2017

Florida’s Open House Party Statute: Don’t Be The “Cool” Parents!

Many of our friends have “kids” who are in the 18-20 year old range.  Whether they are older high school students or younger college students, many of them want to have “a few friends over” to Mom and Dad’s house.  Spring Break, graduati

04/12/2017

Attorney Ric Keller Discusses State Attorney Aramis Ayala’s Decision To Sue Governor Rick Scott

Check out Ric Keller on this morning’s Fox 35 segment as he discusses recent news of State Attorney, Aramis Ayala’s decision to sue Florida Governor, Ric Scott. https://www.fox35orlando.com/good-day/248107537-video

04/03/2017

Issues To Consider If Your Personal Injury Claimant Is A Medicare Beneficiary, And Is Being Treated Under Letters Of Protection

One of the more challenging aspects of successful claims resolution arises in situations where a personal injury claimant receives medical care and treatment pursuant to letters of protection.  A letter of protection (“LOP”), of course, is an a

03/24/2017

Construction Liens: How Do You Prove The Date Of “Final Furnishing?”

Most construction folks in Florida know that to lien a job, the lienor must file its lien within 90 days of ….something.  An unpaid lienor usually starts focusing on this question sometime after its pay application hasn’t been paid for a month

01/26/2017

Chris Hill Receives Golden Gavel Award

HRKM Partner, Chris Hill, was recently awarded Westfield Insurance Company’s Golden Gavel Award! Presented by Jim Schumaker, the Golden Gavel was given to Chris for his outstanding handling of a claim on behalf of Westfield. We want to congratula

12/20/2016

Happy Holidays from Everyone at HRKM

Wishing you and your family happiness this Holiday Season and throughout the coming year from all of us at Hill, Rugh, Keller & Main!

12/05/2016

HRKM Owner, Chris Hill Participates in Charity Golf Scramble

HRKM Owner and Partner, Chris Hill and friends participated in BASE Camp Children’s Cancer Foundation‘s Golf Scramble this past weekend. HRKM was honored to sponsor this organization which supports children and their families going tho

11/20/2016

HRKM Attorneys Attend OCBA Event in Downtown Orlando

HRKM Attorneys, Nick Patrick, Andrew Showen and Scott Reed had the privilege of attending the Orange County Bar Association’s Joint Voluntary Happy Hour in Downtown Orlando last night. Thank you to the OCBA for hosting such a great event!

11/03/2016

Hurricane Matthew Reminded Us What Insureds Can Lose When They Give Assignments of Benefits

Hurricane Matthew has brought out repair contractors offering services to property owners who have suffered damages to their homes, businesses and condominiums.  Already we’ve seen one form of agreement between a repair contractor and a condomini

10/21/2016

Partners & Staff of HRKM Show Support for Breast Cancer Awareness

In recognition of Breast Cancer Awareness Month, partners and staff of Hill, Rugh, Keller & Main, P.L. “pink-out” the office in Orlando. #BreastCancerAwarenessMonth #PinktoberOrlando

09/28/2016

Employee Or Independent Contractor: What You Need To Know

The issue of whether an individual is an employee or an independent contractor for liability purposes is not always clear-cut. To resolve the issue, Florida courts apply a multifactor test, with the most important factor being the “extent of contr

09/12/2016

HRKM Attorney’s Winning Verdict in Asian Antiques Case

Chris Hill recently won a jury trial in a commercial litigation case for a local antiques dealer.  HRKM filed suit on behalf of a family-owned Winter Park company, seeking to collect more than $1 million from purchasers located in Chicago.  Th

08/24/2016

Aerial Photos Provide Inexpensive and Compelling Evidence

HRKM lawyers used aerial photography taken over time in a recent trial to prove that a property had numerous gaps in a fence line which the plaintiff claimed was secure.  In the above photo from property appraiser’s public records, one can se

08/15/2016

HRKM Staff Attends Popular Networking Event in Orlando

Partner, Ric Keller and staff of HRKM had the privilege of attending TCU Construction’s Networking Event at Bar Louie last Thursday. Our staff had an amazing time meeting everyone who participated in this occasion!

08/03/2016

HRKM Lawyers Recover Costs From Plaintiff After Dismissal of Warehouse Fire Case

Chris Hill and Andy Showen secured a judgment of dismissal at the close of plaintiff’s case in a Federal court trial in Orlando in December 2015.  The court taxed defense costs against the plaintiff of over $17,000 in post-trial proceedings, whic

07/19/2016

Can Legal Draftsmanship Fix The Florida Constitution Statute of Repose Problem?

We often hear that Florida has a ten year statute of repose for claims arising out of construction.[1]  Contractors design their risk management plans (such as they are) assuming there is an absolute ten year bar against lawsuits.  But the ten yea

04/07/2016

“What Do You Mean We Have To Go To Pennsylvania To Enforce Our Warranty?”: Roof Replacement, Venue Clauses, Warranty Limitations, And Other Pitfalls In Condominium Repair Contracts

The Life and Death of a Roof: A condominium building with a low-slope roof (commonly but incorrectly referred to as a “flat” roof) will need a reroof every seven to twenty years. This is a major budget item that can cost from $8 to $15 per squar

04/07/2016

Performance Bonds , Indemnity Agreements and Contractor’s Spouses

Building contractors often have to provide performance bonds to owners. Do their spouses understand they are cosigning for those bonds and may lose their homes and personal assets when obtaining the bond? Contractors’ spouses’ risk on bon