Universal Plant Services of Nashville, Inc. v. Boland Trane Services, Inc.
8:21-cv-01188
D. MarylandAug 6, 2024Background
- Universal Plant Services of Nashville (“Universal”) was subcontracted by Boland Trane Services, Inc. (“Boland”) to remove, repair, and reinstall a turbine on a University of Maryland chiller system as part of a refurbishment project for Engie-College Park Energy, LLC.
- Universal failed to properly align the turbine to the compressor upon reinstallation, breaching its contract with Boland.
- Boland, under time pressure from Engie, chose to operate the chiller out of alignment despite being warned of the risks, resulting in catastrophic equipment failure.
- Universal sought payment for its work, while Boland counterclaimed for contract and tort damages resulting from the failure.
- The parties agreed Maryland law applied and the case was tried to the bench, with the district court making findings of fact and law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Breach of Contract – Payment | Universal: Boland owes payment for completed work. | Boland: Universal materially breached by failing to align, excusing payment. | Universal’s breach was material; Boland does not owe payment. |
| Breach of Contract – Damages | Boland: Universal’s breach caused catastrophic failure and damages. | Universal: Damages result from Boland operating misaligned chiller, not breach. | Boland’s damages not proximately caused by Universal; no recovery. |
| Negligence | Boland: Universal owed/violated a duty of care independent of the contract. | Universal: No independent duty exists; relationship governed solely by contract. | No independent tort duty; negligence claim fails. |
| Contributory Negligence/Assumption of Risk | Boland: Universal had last clear chance to avert harm. | Universal: Boland’s own negligent and voluntary conduct bars recovery. | Boland contributorily negligent and assumed risk; cannot recover. |
Key Cases Cited
- Taylor v. NationsBank, N.A., 365 Md. 166 (Md. 2001) (defining breach of contract requirements under Maryland law)
- Mesmer v. Maryland Auto. Ins. Fund, 353 Md. 241 (Md. 1999) (duty of care in negligence requires independent basis beyond contract)
- Jacques v. First Nat. Bank of Md., 307 Md. 527 (Md. 1986) (discussing when tort duties arise in contractual relationships)
- Campfield v. Crowther, 252 Md. 88 (Md. 1969) (explaining Maryland’s contributory negligence doctrine)
- St. Paul Fire & Marine Ins. v. House, 315 Md. 328 (Md. 1989) (material breach excuses other party’s performance)