Henry Enterprises v. King Mechanical: Maryland Court Remands Contract Dispute

Henry Enterprises LLC, also known as Henry Enterprise LLC, provided HVAC services for a construction project located at 525 Aisquith Street in Baltimore, Maryland. King Mechanical Company, Inc. hired Henry Enterprises to perform the HVAC work in December 2021. The agreement required King Mechanical Company to make payments every fifteen days for work performed.

In May 2022, the parties executed a written amendment to the contract. The amendment increased the total contract price to $422,480 and included a change order reflecting an adjustment related to commercial wage rates for the project. Henry Enterprises completed the HVAC work covered by the agreement and submitted invoices seeking payment of the full amended contract amount.

Henry Enterprises later asserted that it received only $349,042.90 in payments and that a substantial balance remained unpaid under the amended agreement.

Claims Asserted in State Court

Henry Enterprises filed a civil action in Maryland state court asserting claims for breach of contract, quantum meruit, and unjust enrichment. The claims sought recovery of the unpaid balance allegedly owed under the amended subcontract.

The complaint did not reference federal statutes or wage enforcement actions. It focused on the existence of the amended agreement, the work performed, the payments received, and the remaining amount allegedly due.

King Mechanical Company removed the case to the United States District Court for the District of Maryland, asserting that the dispute raised a federal question.

Motion for a More Definite Statement

After removal, King Mechanical Company filed a motion seeking a more definite statement. King Mechanical Company asserted that, in December 2022, it paid $62,840.21 to the Maryland Department of Labor to satisfy an unpaid wage determination associated with the project. King Mechanical Company maintained that this payment should be credited against the amount owed under the amended contract.

Henry Enterprises disputed that the payment constituted an offset under the contract. The motion for a more definite statement asserted that Henry Enterprises relied on the Davis-Bacon Act when disputing the offset.

The district court concluded that the complaint adequately stated the basis of the claims. The court explained that the dispute concerned whether the amended contract required payment of the full $422,480 and whether any subsequent payment to the Maryland Department of Labor reduced that obligation. The court determined that the complaint provided sufficient notice of the claims and denied the motion for a more definite statement.

Motion to Remand and Jurisdictional Analysis

Henry Enterprises also moved to remand the case to state court. The motion asserted that the complaint raised only state-law claims and did not present a federal question. Henry Enterprises also asserted that removal was untimely.

The district court applied the well-pleaded complaint rule when analyzing federal question jurisdiction. The court determined that the complaint asserted only state-law causes of action and did not rely on federal law as a necessary element of any claim. The court concluded that potential defenses involving federal statutes did not create federal jurisdiction.

The court also reviewed the timing of removal. King Mechanical Company did not remove the case within thirty days of service. The court rejected the argument that a later discussion between counsel triggered a new removal period.

The Court’s Ruling

The district court denied the motion for a more definite statement and granted the motion to remand. The court ordered the case returned to the Circuit Court for Baltimore County, Maryland, and closed the federal action.

Assistance With Contract Dispute Matters

If you’re dealing with contract disputes involving payment disagreements, subcontractor issues, or construction-related claims, Whitcomb Selinsky PC handles contract dispute matters. Reach out to our team to schedule a consultation and learn how our team can assist with your situation.