Justia Contracts Opinion Summaries

WPX Energy, a non-Indian oil and gas company, obtained rights-of-way from the Bureau of Indian Affairs to access land owned by members of the Three Affiliated Tribes on the Fort Berthold Reservation. The Fettigs, tribal members and landowners, consented to the grants and also entered into side letter agreements with WPX Energy, imposing conditions such as prohibiting smoking and hunting, and specifying fines for violations. In 2020, the Fettigs filed suit in the Three Affiliated Tribes District Court, alleging WPX Energy violated the no-smoking provision. WPX Energy argued that the tribal court lacked jurisdiction, as it is a non-Indian entity, but the tribal district court, through Judge Jones, found it had jurisdiction under the Montana consensual relationship exception. The Fettigs also pursued an administrative claim with the Bureau, which was denied on the basis that the side letter agreements were not incorporated into the grants.WPX Energy sought a preliminary injunction in the United States District Court for the District of North Dakota, claiming the tribal court lacked jurisdiction. The district court granted the injunction, but the United States Court of Appeals for the Eighth Circuit previously vacated it, requiring exhaustion of tribal remedies. After the Three Affiliated Tribes Supreme Court affirmed tribal jurisdiction, WPX Energy again sought relief in federal court, which again granted a preliminary injunction. Judge Jones appealed this second grant.On review, the United States Court of Appeals for the Eighth Circuit held that the tribal court had jurisdiction under the first Montana exception because the dispute arose from a commercial relationship created by the side letter agreements, which were independently negotiated and not governed by federal law. The court also found that normal litigation costs did not constitute irreparable harm. The Eighth Circuit vacated the preliminary injunction and remanded for further proceedings. View "WPX Energy Williston, LLC v. Jones" on Justia Law

A woman executed a will leaving most of her estate to her daughter-in-law, Cheryl, and nearly disinheriting her two surviving children, Margo and Gary. Prior to her death, Margo became her guardian and conservator, and initiated legal action against Cheryl for alleged financial exploitation. The parties settled, with Cheryl confessing judgment for a sum of money, but the settlement agreement stipulated that neither Margo nor the estate would seek to collect on the judgment. The will contained a Nebraska choice-of-law provision, and after the woman passed away in Kansas, the dispute over distribution of her estate and the effect of the confessed judgment continued in both Kansas and Nebraska courts.The Sedgwick District Court in Kansas initially granted Margo and Gary’s request to set off Cheryl’s confessed judgment against her share of the estate. Cheryl then sought ancillary probate in Nebraska, where the court distributed Nebraska property to her and, after interpreting the settlement agreement, denied Margo and Gary's setoff claim. Based on this Nebraska ruling, the Kansas district court reconsidered and denied the setoff request, ordering distribution pursuant to the will. Margo and Gary appealed, and the Kansas Court of Appeals reversed, holding that Cheryl's confessed judgment was a debt owed to the estate and must be set off under Kansas law.The Supreme Court of the State of Kansas reviewed the appeal. It held that a right of setoff against a beneficiary’s distributive share requires an actual debt owed to the estate. Because the Nebraska court had interpreted the settlement agreement to mean Cheryl’s confessed judgment was not a debt due and owing to the estate, the Kansas Supreme Court deferred to that interpretation under principles of comity and Nebraska law. Consequently, there was no debt subject to setoff, and the Supreme Court reversed the Court of Appeals and affirmed the district court’s denial of setoff. View "In re Estate of Mueller " on Justia Law

A group of utility companies operating nuclear power plants in Maine, Connecticut, and Massachusetts entered into contracts with the Department of Energy (DOE) requiring DOE to dispose of their spent nuclear fuel (SNF) in exchange for fees paid into a federal fund. DOE failed to meet its obligations, resulting in the utilities retaining and storing SNF on-site beyond their planned plant decommissioning. To ensure funds for safe decommissioning and continued SNF storage, the utilities established nuclear decommissioning trusts (NDTs), funded by electricity ratepayers and managed according to federal regulations. These trusts generated significant investment gains, which were used to pay for ongoing SNF storage expenses.Previously, the United States Court of Federal Claims and the United States Court of Appeals for the Federal Circuit found DOE in partial, ongoing breach of the contracts, awarding damages to the utilities for costs incurred due to the breach. In the current claim period (2017–2021), the utilities sought reimbursement for $145 million in SNF storage costs. DOE conceded liability but argued that the investment gains from the NDTs should be credited against damages, effectively reducing its liability to zero. The Court of Federal Claims rejected this argument, granting summary judgment to the utilities and entering judgment for the full $145 million, subject to appeal.The United States Court of Appeals for the Federal Circuit reviewed the Court of Federal Claims’ grant of summary judgment de novo. It held that the investment gains from the NDTs are not “mitigation” of damages and cannot be set off against the utilities’ breach-induced expenses, because the gains did not reduce or avoid losses caused by DOE’s breach and were not directly related to the breach. The court affirmed the judgment, requiring DOE to reimburse the utilities for their SNF storage costs without offset for NDT investment earnings. View "CONNECTICUT YANKEE ATOMIC POWER CO. v. US" on Justia Law

A dispute arose between two parties over a residential lease agreement in Mountain Home, Idaho, which included an option to purchase the property after the underlying Wells Fargo mortgage was satisfied. The lessee paid $8,000 for the purchase option and began residing at the property. Eighteen months later, the lessee filed for Chapter 7 bankruptcy, listing the lessor as a creditor and rent as an expense but denying any legal or equitable interest in real property and failing to disclose the lease agreement or the purchase option in the bankruptcy schedules. The bankruptcy trustee closed the case without distributing any assets, and the lessee received a discharge of debts. Four years after discharge, the lessee attempted to exercise the purchase option, but the lessor refused.The lessee filed suit in the District Court of the Fourth Judicial District, seeking specific performance and declaratory relief, while the lessor counterclaimed for breach of contract. Both parties moved for summary judgment. The district court initially denied both motions, finding factual disputes, and declined to apply judicial estoppel. Upon reconsideration, the district court ruled for the lessor, holding that the lessee’s claims were barred by judicial estoppel and, in the alternative, that the lessee lacked standing because the undisclosed purchase option remained property of the bankruptcy estate. The district court denied the lessee’s request to stay the proceedings to reopen the bankruptcy case.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s judgment, holding that the lessee lacked standing to enforce the purchase option. The court reasoned that the purchase option was property of the bankruptcy estate, was not properly disclosed in the bankruptcy schedules, and thus remained with the estate after the bankruptcy case closed. Only the bankruptcy trustee, not the lessee, had standing to enforce the option. Costs on appeal were awarded to the lessor. View "Conger v. Clark" on Justia Law

Dr. Lesley Williams, a second-year anesthesiology resident at Augusta University, experienced a traumatic assault and was subsequently diagnosed with PTSD. She requested modified duties and accommodations, but the residency program placed her in observer roles and required fitness-for-duty evaluations. Williams filed complaints regarding denial of academic credit and alleged discrimination based on sex and disability. Faculty raised concerns about her professionalism, clinical judgment, and exam conduct. Williams was suspended and ultimately terminated from the residency program after loss of clinical privileges, but an ad hoc committee initially recommended reinstatement with zero tolerance for further unprofessional behavior. Following further faculty concerns, Williams was again suspended and terminated.Williams appealed her termination through Augusta University’s internal procedures. The ad hoc committee found her clinical evaluations were generally adequate, but noted serious concerns about exam misconduct. Dean Hess ordered her reinstatement with strict conditions, but after additional negative evaluations and faculty meetings, Williams was suspended and terminated for patient safety reasons. She appealed to the University President and the Board of Regents of the University System of Georgia, both of whom upheld her termination.The United States Court of Appeals for the Eleventh Circuit reviewed the district court's grant of summary judgment in favor of the Board of Regents on Williams’s claims, which included sex discrimination, retaliation, disability discrimination, whistleblower retaliation, denial of procedural due process, and breach of contract. The Eleventh Circuit held that Williams failed to establish the required elements for each claim, including the lack of similarly situated comparators, absence of evidence supporting discriminatory or retaliatory intent, and insufficient support for procedural or contractual violations. The court affirmed the district court’s grant of summary judgment on all claims. View "Williams v. Board of Regents of the University System of Georgia" on Justia Law

Four law firms jointly represented a client in a federal court case against Iraq, resulting in a substantial judgment in favor of their client. Prior to seeking attorneys’ fees, the firms executed an Agreement Concerning Attorneys’ Fees (ACAF), which provided for a forty-six percent contingency fee and included an arbitration clause. Disputes arose regarding the allocation of the fee, particularly after some firms allegedly negotiated a side agreement to increase their shares. One firm, believing its share was subject to future negotiation, did not seek fees in arbitration and was awarded none by the arbitrator.After the arbitration, Quinn, Racusin & Gazzola Chartered (QRG) moved in the Superior Court of the District of Columbia to vacate the arbitrator’s final award, arguing the ACAF was invalid due to fraudulent inducement and duress, and that the arbitrator had exceeded the scope of authority under the agreement. Appellees disputed these claims and sought confirmation of the award. The Superior Court determined that QRG had not established fraud or duress and found the arbitration clause broad enough to encompass both the fee allocation dispute and related tort claims. The court denied QRG’s motion to vacate and confirmed the arbitration award.On appeal, the District of Columbia Court of Appeals reviewed de novo the legal conclusions regarding fraud, duress, and the scope of the arbitration clause. The court held that QRG failed to demonstrate fraudulent inducement or duress in execution of the arbitration clause. It further held that the arbitrator acted within the scope of the ACAF’s arbitration clause, which covered the fee allocation dispute and related tort claims. The Court affirmed the Superior Court’s judgment confirming the arbitrator’s final award. View "Quinn, Racusin & Gazzola Chartered v. Pavich Law Group, P.C." on Justia Law

Sonia Breslow purchased a $250,000 watch from Jacob & Company, which was shipped from New York to the Iron Horse Golf Club in Montana. The Club repackaged the shipment and sent it via Federal Express (FedEx) “priority overnight” to a UPS store in Arizona. The shipping label did not declare a value for the package. Video evidence showed that after FedEx took possession, the yellow bag containing two boxes was no longer secured by a zip tie, and at the Scottsdale facility, an employee removed one box from the bag. Ultimately, FedEx delivered the bag to the UPS store, but the watch was missing. Sonia filed an insurance claim, and Pennsylvania Insurance paid the Breslows the purchase price, then sued FedEx as their subrogee.Pennsylvania Insurance initially brought claims for negligence, conversion, unjust enrichment, breach of contract, and civil theft in Nebraska state court. FedEx removed the case to the United States District Court for the District of Nebraska. The district court ruled that the Airline Deregulation Act preempted the claims for negligence, unjust enrichment, and civil theft, dismissed the conversion claim for lack of evidence, and found breach of contract but limited FedEx’s liability under the shipping contract to $100. The case proceeded to a bench trial, where the court found the breach and upheld the liability limit, entering judgment for Pennsylvania Insurance in the amount of $100.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s rulings. The court held that the Airline Deregulation Act preempts state-law claims relating to FedEx’s package handling and transportation services. It found no error in the district court’s dismissal of the conversion claim and upheld the liability limit of $100, concluding that the Club had adequate notice and opportunity to purchase greater coverage. The court also affirmed that Pennsylvania Insurance had standing as subrogee and that FedEx breached the contract. View "Pennsylvania Insurance Co. v. Federal Express Corp." on Justia Law

A former employee entered into a noncompete agreement with his employer, which barred him from engaging in similar business activities for 12 months within the company’s client base area after his employment ended in April 2024. Months later, the employer alleged that the former employee and his new business violated the agreement and sought a temporary restraining order (TRO) and a preliminary injunction to enforce it. After the parties exchanged filings, the district court issued a TRO in June 2025, set to remain in effect indefinitely, and delayed the hearing on the preliminary injunction multiple times, citing new evidence related to a superseding noncompete agreement.The district court clarified the TRO’s scope, found the petitioners in contempt for violating it, and denied their motion to dissolve the TRO. The court eventually allowed the employer to amend its complaint to reflect the new agreement and later issued an amended TRO. A preliminary injunction was finally issued in April 2026. The petitioners challenged the original TRO by writ petition, arguing that it exceeded the 14-day limit allowed by Nevada Rule of Civil Procedure 65(b).The Supreme Court of Nevada reviewed the case and clarified that, under NRCP 65(b)(2), the 14-day time limit applies to TROs regardless of whether they are issued with or without notice. The court held that a TRO cannot be indefinite and must expire after 14 days unless properly extended for good cause or by consent. Because the district court’s TRO was indefinite and not properly extended, it automatically expired 14 days after issuance. The Supreme Court of Nevada granted the writ of mandamus and directed the district court to declare the TRO expired as of June 23, 2025. View "HAVENS VS. DIST. CT." on Justia Law

The case involves a dispute between an individual who spent several years assisting a businessman and his associates in acquiring satellites, with the expectation of future compensation. The parties discussed compensation on various occasions, culminating in an oral agreement that included equity interests and a corporate position for the plaintiff. However, the agreement was never formalized in writing, and the promises were not fulfilled. The plaintiff eventually filed suit seeking compensation for his efforts under several legal theories, including breach of contract, unjust enrichment, promissory estoppel, and fraud.In the Superior Court of the District of Columbia, the case went through several judges. Initially, summary judgment was denied, but after rulings that excluded certain witness testimony—especially the plaintiff’s damages expert—the court ultimately granted summary judgment for the defendants on most claims. The claims for unjust enrichment and promissory estoppel survived, but the plaintiff voluntarily dismissed them to expedite an appeal.The District of Columbia Court of Appeals reviewed the summary judgment rulings. The appellate court agreed with the lower court that the statute of frauds barred the breach of contract and implied contract claims, as the alleged oral agreement could not be performed within one year and no exception applied. The court upheld summary judgment on the fraud claim due to insufficient evidence of fraudulent intent. However, the court reversed summary judgment on the unjust enrichment and promissory estoppel claims, finding genuine disputes of material fact that should be resolved by a factfinder. The appellate court also upheld restrictions on certain lay testimony but vacated limitations on the expert’s damages testimony, remanding the case for further proceedings. View "Farooqui v. Silkwave Holdings Ltd." on Justia Law

A licensed emergency room physician entered into an independent contractor agreement with a medical staffing company to provide services at a hospital’s emergency department. After a patient complained about the physician’s conduct, the hospital instructed the staffing company to remove him from the schedule, and the company subsequently terminated his agreement following its own investigation. The physician brought suit against the hospital, its medical staff, and the staffing company, alleging that his removal from the schedule occurred without the notice or hearing required by statutory and common law fair procedure rights. The claims against the hospital and medical staff were settled and dismissed, leaving the staffing company as the sole defendant.The Superior Court of Kern County considered the staffing company’s motion for summary judgment. The court denied summary judgment, granted summary adjudication in favor of the staffing company on the intentional infliction of emotional distress claim, but denied summary adjudication on the claim for violation of the common law right of fair procedure, allowing that claim to proceed. The staffing company then sought a writ of mandate from the California Court of Appeal, Fifth Appellate District, challenging the denial as to the fair procedure claim.The California Court of Appeal, Fifth Appellate District, held that the common law right of fair procedure does not apply to the staffing company as a matter of law. The court reasoned that the staffing company was not a quasi-public institution or peer review body as defined by statute, nor did it have the power to foreclose the physician’s ability to practice medicine broadly. The court ordered that the trial court’s denial of summary judgment be vacated and that judgment be entered for the staffing company on all claims. The stay previously issued was lifted, and the staffing company was awarded costs in the proceeding. View "Stallion Springs Medical Services v. Super. Ct." on Justia Law