Stanley Builders, Inc. v. Nacron

Stanley Builders, Inc. (Stanley) (plaintiff) entered into a construction contract to build a house for Julian and Sydonia Nacron (defendants). During construction, Stanley acquired hardware items from Architectural Hardware and Lighting, Inc. (AHL). Stanley completed construction and the Nacrons moved into the newly built home. However, after the Nacrons refused to pay the remaining approximately $19,500 due on Stanley’s construction bill, Stanley sued the Nacrons in circuit court to foreclose a mechanics’ lien on the property. The Nacrons countered, arguing that Stanley was not currently owed the $19,500 because he had not yet completed all work under the construction contract. During the pendency of Stanley’s action, AHL sued both Stanley and the Nacrons in county court to recover approximately $900 in outstanding charges for delivered hardware. Stanley filed a crossclaim against the Nacrons in AHL’s county-court action, arguing that any judgment rendered against Stanley should be enforced against the Nacrons because Stanley purchased the hardware from AHL for use in the Nacrons’ construction project. The county court (1) entered judgment against Stanley; and (2) granted Stanley’s crossclaim and ordered the Nacrons to pay the $900. Subsequently, the Nacrons filed an amended answer in Stanley’s circuit-court claim, arguing that Stanley’s circuit-court action should be dismissed because, by filing the crossclaim in the AHL action, Stanley had impermissibly split his cause of action. The circuit court dismissed Stanley’s case, holding that the crossclaim split Stanley’s action and, therefore, recovery on the crossclaim precluded Stanley from seeking additional recovery in circuit court. Stanley appealed, and the appellate court affirmed without an opinion. Stanley appealed to the Florida Supreme Court.