Stanley Builders, Inc. v. Nacron
1970 Fla. LEXIS 2676, 238 So. 2d 606 (1970)
Sections
Rule of Law:
The rule against splitting causes of action is not absolute and should not be applied to bar a claim where the assertion of a cross-claim in a separate, pending action did not result in a multiplicity of suits or unnecessary harassment of the defendant.
Facts:
- Stanley Builders entered into a contract to construct a residence for Julian and Sydonia Nacron.
- Stanley Builders completed the construction work.
- The Nacrons occupied the premises but refused to pay the remaining balance of $19,416.36 due under the contract.
- Separately, a third-party supplier, Architectural Hardware and Lighting, Inc., sold and delivered specific hardware items for the home to Stanley Builders and the Nacrons.
- Architectural Hardware was not paid the $930.36 owed for these specific materials.
Procedural Posture:
- Stanley Builders filed a lien foreclosure suit against the Nacrons in the Circuit Court of Dade County.
- Architectural Hardware filed a separate suit against Stanley Builders and the Nacrons in the Civil Court of Record.
- Stanley Builders filed a cross-claim against the Nacrons in the Civil Court of Record action.
- The Civil Court of Record entered summary judgment for Stanley Builders on the cross-claim, which was satisfied.
- The Nacrons amended their answer in the Circuit Court action to assert that the Civil Court judgment constituted a 'splitting of the cause of action' barring further relief.
- The Circuit Court dismissed Stanley Builders' complaint with prejudice.
- The District Court of Appeal, Third District, affirmed the dismissal.
- Stanley Builders petitioned the Supreme Court of Florida for a writ of certiorari.
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Issue:
Does the rule against splitting causes of action bar a plaintiff from pursuing a primary lawsuit for a contract balance if they subsequently assert and win a cross-claim regarding a specific subcontractor's bill in a separate, third-party lawsuit involving the same contract?
Opinions:
Majority - Justice Boyd
No, the rule against splitting causes of action does not bar the plaintiff's primary claim in this specific context. The Court reasoned that the fundamental purpose of the rule is to ensure litigation has an end and to prevent a defendant from being harassed by a multiplicity of suits. In this instance, the plaintiff did not initiate a second lawsuit to harass the defendants; rather, the plaintiff utilized a cross-claim in a suit already filed by a third party (Architectural Hardware). Because the assertion of this cross-claim did not create a new or separate proceeding, the reasoning behind the prohibition on splitting causes of action does not apply. Furthermore, the Court held that applying the rule rigidly in this scenario would be 'manifestly unjust,' as it would extinguish a legitimate claim for over $19,000 simply because the plaintiff successfully resolved a minor $930 dispute in a concurrent action.
Dissenting - Justice Thornal
No opinion text provided; noted only as dissenting.
Analysis:
This decision represents a significant equitable limitation on the procedural doctrine of 'splitting a cause of action.' By prioritizing the 'ends of justice' over rigid procedural adherence, the Florida Supreme Court established that the defense of res judicata (specifically regarding claim splitting) must be analyzed based on its purpose—preventing harassment—rather than as a technical trap. This protects contractors and businesses who may be involved in complex, multi-party litigation (like construction disputes with multiple subcontractors) from inadvertently waiving their primary claims when defending against smaller third-party suits. It encourages efficiency by allowing parties to resolve sub-issues via cross-claims without fear of forfeiting their main cause of action.
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