Justia Contracts Opinion Summaries

A group of Guatemalan nationals were recruited under the H-2A visa program by a Michigan agricultural company and its owners to work seasonal jobs between 2017 and 2019. The plaintiffs alleged that the defendants illegally charged recruitment fees, underpaid wages, forced them to live in poor conditions, confiscated personal documents, limited their freedom, and threatened them with deportation if they complained. The plaintiffs claimed these actions violated federal anti-trafficking laws, the Fair Labor Standards Act, Michigan labor and trafficking statutes, and state contract law.In the United States District Court for the Western District of Michigan, the case proceeded to a jury trial. The jury found in favor of the plaintiffs on most claims, awarding both compensatory and punitive damages, while denying certain claims against one defendant and rejecting the defendants’ counterclaims. The district court denied the defendants’ motions for mistrial, to dismiss for forum non conveniens, for a new trial, and for remittitur of punitive damages. The court entered judgment for the plaintiffs, including damages, attorney fees, and costs.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the punitive damages awarded were not grossly excessive or arbitrary and thus did not violate due process, applying the guideposts from BMW of North America, Inc. v. Gore and State Farm Mutual Automobile Insurance Co. v. Campbell. The court also found no abuse of discretion in the district court’s evidentiary rulings, denial of a mistrial, or in allowing the case to proceed in Michigan rather than Guatemala. The court further concluded that alleged statute of limitations defenses were either inapplicable or waived. The Sixth Circuit affirmed the district court’s judgment in all respects. View "Gomez-Echeverria v. Purpose Point Harvesting, LLC" on Justia Law

Cheryl Walker used her Uber account to order a guest ride for her husband, Carroll Walker. Carroll had never downloaded the Uber app or created an account, and he consistently stated that he does not read or reply to text messages. On the relevant occasion, Cheryl ordered a ride for Carroll, and Uber sent Carroll a text message with ride details and a hyperlink to its Terms of Use, which included an arbitration provision. Carroll did not see the message. During the ride, an accident occurred, allegedly due to the driver’s distraction by Uber’s app, resulting in severe injuries to Carroll.In the United States District Court for the District of Columbia, Cheryl Walker sued Uber on Carroll’s behalf, asserting negligence and products liability claims. Uber moved to compel arbitration, arguing Carroll was bound to arbitrate either because he had notice of the Terms via Uber’s text message or as a third-party beneficiary of Cheryl’s contract with Uber. The district court denied Uber’s motion, finding Uber failed to establish that Carroll was on inquiry notice of the Terms and concluding that Carroll was not bound as a third-party beneficiary or estopped from refusing arbitration.The United States Court of Appeals for the District of Columbia Circuit reviewed the district court’s denial of Uber’s motion to compel arbitration de novo, applying D.C. contract law. The Court held that Uber had not shown Carroll agreed to be bound by its Terms of Use, as Carroll lacked actual or inquiry notice of the Terms. The Court further determined that Carroll was not bound by Cheryl’s contract as a third-party beneficiary or by equitable estoppel, since Carroll was not seeking to enforce Cheryl’s contract and his claims were independent of it. The judgment of the district court was affirmed. View "Walker v. Uber Technologies, Inc." on Justia Law

T-Mobile and KAIFI settled a patent infringement lawsuit involving claims of U.S. Patent No. 6,922,728, which covers Wi-Fi calling technology. As part of their settlement, T-Mobile agreed to make two payments: one immediate payment and another conditional payment, the latter to be made if any of the asserted patent claims “survived” an ex parte reexamination (EPR) at the United States Patent and Trademark Office. After the Patent Office confirmed the patentability of most of the asserted claims without amendment, T-Mobile refused to make the additional payment, arguing that the claims had not truly “survived” the EPR due to alleged changes in claim scope and supposed inequitable conduct by KAIFI during the reexamination.T-Mobile filed a declaratory judgment action in the United States District Court for the Eastern District of Texas, seeking a determination that it had not breached the settlement agreement by withholding the payment. The district court granted summary judgment for KAIFI, holding that the settlement agreement was clear: a claim “survives the EPR” if the Patent Office confirms its patentability in the Reexamination Certificate. The court found T-Mobile’s arguments about claim scope and inequitable conduct irrelevant to the payment obligation and ordered T-Mobile to make the additional payment.On appeal, the United States Court of Appeals for the Federal Circuit reviewed whether it had subject-matter jurisdiction. The court determined that the dispute centered on the interpretation of a contract governed by Texas law and did not necessarily involve a substantial question of federal patent law. Consequently, the court held that it lacked appellate jurisdiction and transferred the case to the United States Court of Appeals for the Fifth Circuit, which has jurisdiction over appeals from the Eastern District of Texas. View "T-MOBILE US, INC. v. KAIFI LLC " on Justia Law

A plaintiff leased a new vehicle from a dealership and soon experienced significant problems, including charging failures, starting difficulties, and an event involving fire risk. Despite attempts at repair by the dealership and authorized facilities, the vehicle remained inoperable. The plaintiff’s lease included an arbitration provision broadly defining disputes to include claims concerning the vehicle’s condition and warranties. The plaintiff sued the vehicle manufacturer under California’s Song-Beverly Consumer Warranty Act for a range of statutory violations related to the vehicle’s defects and warranty service.The Santa Clara County Superior Court denied the manufacturer’s motion to compel arbitration. The trial court reasoned that the manufacturer could not enforce the arbitration agreement as a third party beneficiary under the rationale of Ford Motor Warranty Cases, because the plaintiff’s statutory claims arose from the manufacturer’s obligations under the Song-Beverly Act, not from the lease itself. The court also rejected the manufacturer’s equitable estoppel argument, and, finding no enforceable arbitration agreement between the parties, declined to address issues of unconscionability or delegation.The California Court of Appeal, Sixth Appellate District, reviewed the matter. It held that the manufacturer was in fact a third party beneficiary of the arbitration provision, as the lease explicitly defined the manufacturer as a party entitled to enforce arbitration and covered disputes involving the vehicle’s condition and warranties. The court distinguished the California Supreme Court’s decision in Ford Motor Warranty Cases, finding it inapplicable where the manufacturer is named in the lease. The Court of Appeal reversed the trial court’s order and remanded the case for the trial court to decide whether the arbitration provision’s delegation clause is unconscionable. The appellate court expressed no opinion on unconscionability, leaving that issue for the trial court. View "Srivastava v. BMW of North America" on Justia Law

A defendant pleaded guilty to attempted battery with substantial bodily harm, an offense that can be classified as either a gross misdemeanor or a felony. In exchange for the guilty plea, the State agreed to recommend the lesser gross misdemeanor classification and a sentence of 225 days in county detention. The plea agreement included a clause stating that if the defendant failed to appear at any subsequent hearing, the State would be released from its promises under the agreement and could argue for any legal sentence. After pleading guilty, the defendant remained in custody but failed to appear at a continued sentencing hearing because he refused transport from jail, for nonmedical reasons.The Eighth Judicial District Court in Clark County determined that the defendant’s failure to appear constituted a breach of the plea agreement. As a result, the court released the State from its obligations under the agreement, permitting the State to recommend a felony sentence. The State then argued for, and the court imposed, a sentence of 19 to 48 months in prison.The Supreme Court of the State of Nevada reviewed the case and considered whether a failure-to-appear clause in a guilty plea agreement can be enforced against a defendant who remains in custody. The court held that such a clause cannot be enforced against in-custody defendants because they lack control over their appearance in court, and the State retains the means to produce them for hearings. The court vacated the defendant’s sentence and remanded the case for resentencing before a new judge, instructing the State to abide by its original sentencing recommendation. The sentencing judge remains free to determine the appropriate sentence. View "Stafford v. State" on Justia Law

The plaintiff financed his home with a VA loan in 2003, qualifying due to his military service. After failing to make payments for at least ten years, the loan was assigned to HSBC Bank USA and serviced by Specialized Loan Servicing, LLC (SLS). HSBC eventually foreclosed on the property in 2022 and sold it to Northsky, LLC. The VA Servicing Guidelines, which were incorporated into the mortgage contract, required HSBC to notify the plaintiff of the default and explore options to cure it. SLS claimed to have mailed multiple payoff statements and a notice of default to the plaintiff, but he asserted he never received these communications.The plaintiff brought suit in Texas state court against HSBC, SLS, and Northsky, alleging violations of federal and Texas law and seeking to set aside the foreclosure sale. HSBC and SLS removed the case to the United States District Court for the Northern District of Texas. The district court granted partial summary judgment for HSBC and SLS, permitting the plaintiff to proceed on claims for violations of the VA Servicing Guidelines, quiet title, and trespass to try title. At a bench trial, HSBC and SLS presented circumstantial evidence of mailing, relying on business records and testimony from a corporate representative. The district court found this evidence sufficient and, applying the mailbox rule, presumed the plaintiff received the notices, concluding the defendants fulfilled their obligations under the VA Servicing Guidelines.The United States Court of Appeals for the Fifth Circuit reviewed the appeal, applying a deferential standard to the district court’s factual findings. The Fifth Circuit held that the district court correctly applied the mailbox rule based on the evidence presented and that the plaintiff failed to rebut the presumption of receipt. The Fifth Circuit affirmed the district court’s judgment. View "Rummans v. HSBC Bank" on Justia Law

A dispute arose from a vehicle lease agreement, leading Ari Law P.C. to file a Second Amended Complaint in May 2024 against BMW Financial Services NA, LLC and other defendants. Ari Law alleged breach of contract, breach of express and implied warranties, unfair business practices, fraud, and violations of the Rosenthal Fair Debt Collection Practices Act. The San Mateo County Superior Court sustained BMW FS’s demurrer as to counts 2, 3, and 6 (warranty claims and Rosenthal Act claim) without leave to amend. Despite this, Ari Law included these dismissed counts in a Third Amended Complaint filed in September 2024. BMW FS repeatedly requested Ari Law to withdraw the improper claims, but Ari Law refused. BMW FS then served Ari Law with a motion for sanctions under Code of Civil Procedure sections 128.5 and 128.7, initially noticing a hearing for January 17, 2025, and later re-serving and filing the motion with a hearing date of March 18, 2025.The trial court sustained BMW FS’s demurrer to the same counts without leave to amend, and after considering the sanctions motion, imposed monetary sanctions of $29,055 against Ari Law and its counsel. Ari Law challenged the sanctions order, arguing that the notice of motion did not comply with statutory requirements due to differing hearing dates and insufficient time for the safe harbor period. The trial court rejected these procedural objections, finding that Ari Law had adequate notice and opportunity to address the motion, and denied Ari Law’s motion for reconsideration.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. It held that the discrepancy in hearing dates between the served and filed notices did not invalidate the sanctions order, so long as the substance of the motion remained the same and the safe harbor provisions were strictly satisfied. The court affirmed the sanctions order, denied BMW FS’s request for sanctions on appeal, and awarded BMW FS costs. View "Ari Law v. Autonation.com" on Justia Law

A group of Colombian plaintiffs retained two attorneys under a contingency fee agreement to sue a multinational corporation for allegedly funding a paramilitary group that murdered their relatives. The agreement specified that the attorneys would receive one-third of any monetary award obtained before trial. A conflict soon arose between the attorneys after one joined a law firm, leading to disputes over representation and eventual court intervention. The case was consolidated into multidistrict litigation in the United States District Court for the Southern District of Florida, and over time, one attorney was discharged, with the court instructing the discharged attorney’s firm to file a charging lien to preserve its claim for fees and costs.After a settlement was reached that allocated $12.8 million to the plaintiffs and their counsel, the discharged firm moved to enforce its charging lien against the attorney’s share of the recovery. The district court referred the motion to a magistrate judge, who recommended nearly full payment to the firm. The district court adopted this recommendation, ordered the disputed funds to be held in the court registry pending appeal, and required that the funds not be disbursed until appellate review was exhausted.The United States Court of Appeals for the Eleventh Circuit reviewed whether it had jurisdiction to hear an interlocutory appeal of the district court’s order enforcing the charging lien. The Eleventh Circuit held that such orders do not fall within the collateral-order doctrine because they do not resolve important issues separate from the merits and are not effectively unreviewable after final judgment. The court explained that attorneys’ contractual or equitable rights to payment do not implicate substantial public interests or values of a high order and can be adequately reviewed after final judgment. Accordingly, the Eleventh Circuit dismissed the appeal for lack of appellate jurisdiction. View "All Does v. Conrad & Scherer, LLP" on Justia Law

Two individuals, both former members of several Missouri limited liability companies operating as a commercial insurance brokerage, entered into contracts with their company containing Missouri choice-of-law and forum-selection clauses, as well as customer non-solicitation covenants. The agreements required members to follow certain operating agreements, which included a provision allowing termination of membership interests upon 30 days’ notice. Despite this, both individuals resigned “effective immediately” and began working for a competitor. The company sued them in federal court in Missouri to enforce the contractual terms, while the former members filed lawsuits in California state court seeking to void the agreements.The United States District Court for the Western District of Missouri granted summary judgment for the company on the enforceability of the Missouri forum-selection and choice-of-law clauses, finding the individuals breached the forum-selection clauses by suing in California. The court also found the customer non-solicitation covenants enforceable to the extent the company sought to enforce them. However, it granted summary judgment to the former members on claims that they breached the notice provision and related fiduciary duties, and on certain other contract and tort claims. The court awarded the company attorneys’ fees for the Missouri litigation but only nominal damages for the forum-selection clause breaches, declining to award fees incurred in the California actions.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings on the enforceability of the choice-of-law and forum-selection clauses, as well as the customer non-solicitation covenants. It reversed the findings on the notice provision and fiduciary duty, holding these were breached, and directed entry of judgment for the company on those claims. The court vacated the nominal damages for the forum-selection clause breaches, instructing the district court to determine actual damages, and affirmed the attorneys’ fee awards to the company. The case was remanded for further proceedings consistent with these holdings. View "West Series of Lockton Companies, LLC v. Kaufman" on Justia Law

An agricultural supply company sought to recover payment for cattle feed delivered to a dairy farm owned by a married couple, Melissa and Jason. The couple separated in 2018, agreeing that Melissa would no longer be responsible for farm expenses. Jason continued operating the farm, and the company allowed him to accumulate a large debt, expecting it to be paid after the couple’s divorce. Jason died before the divorce was finalized, after which Melissa ceased farming and sold the cattle. The company then sued Melissa to recover the outstanding feed account balance, alleging breach of contract, unjust enrichment, and detrimental reliance.The Vermont Superior Court, Franklin Unit, Civil Division, denied summary judgment for the company on its contract claim and granted partial summary judgment for Melissa, concluding that a novation had occurred, releasing Melissa from future obligations. At trial, the court treated the summary judgment ruling as the law of the case, and ultimately found that a novation occurred when the company and Jason agreed that he alone would pay the debt. The court also found that the company had waived its unjust enrichment claim by not contesting summary judgment on that count and, even had it not, the claim would be barred by unclean hands.On appeal, the Vermont Supreme Court found the trial court erred in concluding a novation had occurred, holding there was no evidence that the company intended to release Melissa from her contractual obligations. The Supreme Court held that, absent evidence of a mutual agreement to discharge Melissa’s obligations, the finding of novation was clearly erroneous. The Court also held that the company failed to preserve its arguments regarding unjust enrichment for appeal. The judgment was reversed and remanded for further proceedings solely on the contract claim. View "Bourdeau Bros., Inc. v. St. Pierre" on Justia Law