In the case of Beacon Residential Community Association v. Skidmore Owings and Merrill et. al. (July 3, 2014, S208173) Cal.4th, a condominium homeowners association, sued the developer of the project and the project architect for construction defects caused by negligent architectural design work. The Supreme Court decision supports all residential homeowners and expands liability for California Architects. The Supreme Court held that architects, when the principal architect on a residential project, owe a duty of care to future homeowners/buyers in the design of residential buildings.
Beacon Residential Community Association filed a lawsuit against the original developers, contractors, and designers alleging construction and design defects. The condominium association alleged that the individual units did not include air conditioning and the windows were so deficient that the individual units experienced excessive heat gain, making them unlivable. The central issue before the Supreme Court was the scope of an architect’s duties and to whom those duties are owed. The Supreme Court held that architects do owe a duty of care to future homeowners based on common law interpretation of duty.
The Court based its ruling on a common law understanding of the scope of a professional’s duty. The Court looked at several factors:
The extent to which the transaction was intended to affect the plaintiff;
The foreseeability of harm to the plaintiff;
The degree of certainty that the plaintiff suffered injury;
The closeness of the connection between the defendant’s conduct;
The injury suffered;
The moral blame attached to the defendant’s conduct; and
The policy of preventing future harm.
After analysis of the above factors, the Supreme Court ruled in favor of the Beacon Condominium Association and found that the Architects owed a duty to the unit homeowners. The Court stated, “Among all the entities involved in the Project, defendants [SOM and HKS Architects] uniquely possessed architectural expertise.” As such, the Court reasoned “an architect cannot escape such liability on the ground that the client makes the final decisions.” The Court reasoned that the architects knew that their design decisions would affect the sale of these condominium units and that the foreseeable buyers of the units were the population of people that could be harmed by the architect’s negligence and who might seek redress against the architects.
The Court held that purchasers of residential units are not in a position to take precautions against design defects. Homebuyers rely on the expertise of the builders and designers that the homes will be designed and built in a fashion that makes them habitable. The Court stated, “A liability rule that places the onus on homebuyers to employ their own architects to fully investigate the structure and design of each home they might be interested in purchasing does not seem more efficient than a rule that makes the architects who designed the homes directly responsible to homebuyers for exercising due care in the first place.”
Benefits For Homeowners
Under the Beacon case, California Homeowners who purchase single family homes or condominium units from developers and builders have the right to sue for design defect claims directly against Architects who designed their home or condominium unit. The Beacon case allows these homeowner lawsuits on residential projects to proceed against the primary designer. This case will enhance the rights of homeowners and require Architects when designing a residential project, to consider the implications of each facet of the architectural design.