Justia Contracts Opinion Summaries
Johnson v. Protective Life Insurance Company
The Eleventh Circuit Court of Appeals ruled on a class action lawsuit that involved a life insurance policy dispute between plaintiff Worth Johnson and defendant Protective Life Insurance Company. Johnson alleged that Protective breached its contract by not reassessing and adjusting its cost of insurance (COI) rates based exclusively on expectations of future mortality experience. The district court granted Protective’s motion for judgment on the pleadings, concluding that Protective did not breach its insurance contract.On appeal, the Eleventh Circuit affirmed the district court's decision in part, agreeing that the policy did not require Protective to reassess and redetermine its COI rates based exclusively on its expectations as to future mortality experience. However, the court reversed the district court's dismissal of Johnson's alternative claim that Protective did reassess and redetermine its COI rates, but ignored its expectations as to future mortality experience when doing so. The court remanded the case for further proceedings consistent with its ruling. View "Johnson v. Protective Life Insurance Company" on Justia Law
BAY, LTD. v. MULVEY
In this case, Bay, Ltd., a construction company, filed suit against The Most Reverend Wm. Michael Mulvey, Bishop of the Diocese of Corpus Christi, seeking to recover the value of unauthorized improvements made to a ranch leased from the Bishop by Michael Mendietta, a former Bay employee. Mendietta had used Bay's resources for these improvements without the company's consent. Bay also filed a separate lawsuit against Mendietta for damages related to his unauthorized actions, including the improvements to the ranch.Six years later, Bay and Mendietta entered into an agreement settling their claims. This agreement required Mendietta to pay Bay $750 per month to avoid a $1.9 million final judgment. The agreement allocated $175,000 of the settlement amount to Mendietta's homestead, but did not allocate specific values to the other injuries suffered by Bay, including the improvements to the ranch.After Bay dropped its claims against Mendietta and proceeded to trial against the Bishop alone, the jury awarded damages to Bay. However, the Bishop requested a settlement credit of $1.725 million (the total settlement amount minus the $175,000 allocated to Mendietta's homestead). The lower court denied this request, but the appellate court reversed, concluding that the unallocated amount of the settlement exceeded the jury's award to Bay.The Supreme Court of Texas affirmed the appellate court's decision, holding that the agreement between Bay and Mendietta constituted a $1.9 million settlement agreement. Because the agreement allocated $175,000 to an injury other than the one Bay sought to recover from the Bishop, the remaining $1.725 million was credited against the jury's verdict, resulting in a take-nothing judgment for Bay. View "BAY, LTD. v. MULVEY" on Justia Law
Columbia Plaza Associates v. Northeastern University
The dispute arose from an agreement between Columbia Plaza Associates (CPA) and Northeastern University regarding the development of a parcel of land in Boston. The contract stipulated that the developer for each phase of the project would be Northeastern or an affiliated entity, which could include CPA. The contract also specified that the developer of the garage parcel would be a joint venture between Northeastern and CPA.CPA claimed that Northeastern violated the agreement when it sought to develop a subparcel unilaterally and repudiated CPA's rights to that subparcel. CPA also argued that Northeastern's communication with a governmental agency amounted to a deceptive business practice.The court held that the agreement did not grant CPA development rights in any of the subparcels except for the garage parcel. The court also found no proof of an enforceable promise by Northeastern to build a hotel with CPA on the disputed subparcel. The court thus ruled in favor of Northeastern on all counts, including CPA's claims for breach of contract, breach of the implied covenant of good faith and fair dealing, intentional interference with advantageous economic relations, unjust enrichment, commercial fraud, unfair or deceptive business practices, and requests for declaratory and injunctive relief.The court further held that Northeastern was entitled to attorney's fees under the anti-SLAPP statute because it successfully dismissed CPA's claim of commercial fraud, which was based solely on Northeastern's petitioning activity. The court did not find CPA's claim to be a SLAPP suit. View "Columbia Plaza Associates v. Northeastern University" on Justia Law
Berlanga v. University of San Francisco
In the case, a group of students from the University of San Francisco (USF) sued the university for breach of contract, alleging that the university did not deliver on its promise to provide in-person instruction and should refund a portion of their tuition fees due to the transition to remote learning during the COVID-19 pandemic. The Court of Appeal of the State of California, First Appellate District, Division Three affirmed the trial court's decision, which granted USF's motion for summary adjudication, concluding that the students failed to raise a triable issue of fact regarding whether USF promised to provide exclusively in-person instruction.The court determined that there was an implied-in-fact contract between USF and the student appellants, established through matriculation and the payment of tuition. However, the court found that the contract did not explicitly promise exclusively in-person instruction. The court also distinguished between general expectations of in-person classes and enforceable contractual promises for exclusively in-person instruction. The court held that the students failed to establish a breach of contract based on the transition to remote learning during the COVID-19 pandemic.The court further held that the students could not pursue quasi-contract claims, as a valid and enforceable contract existed between the students and USF. The students' promissory estoppel claim also failed, as they did not establish any clear and unequivocal promises from USF for in-person instruction. The court stated that the record did not reflect any such promise.The court dismissed the students' claims relating to the Fall 2020 and Spring 2021 semesters, as they were aware these semesters would be conducted either entirely remotely or in a hybrid format prior to enrolling or paying tuition for those semesters. Thus, the students could not reasonably have believed USF contractually promised to provide in-person education for these semesters. View "Berlanga v. University of San Francisco" on Justia Law
Reach Companies, LLC v. Newsert, LLC
In this breach-of-contract dispute, the United States Court of Appeals for the Eighth Circuit upheld the decision of the District Court of Minnesota, which rejected Reach Companies, LLC's appeal for a new trial after a jury awarded $1,196,364 in damages to Newsert, LLC and David Serata. Reach Companies, a distributor of hand sanitizers, alleged that Newsert, a wholesaler of the same products, continued accepting late shipments despite delays and price fluctuations. Newsert countered that Reach failed to fulfill all but one of its purchase orders, causing Newsert to lose two customers. The court found that the purchase orders were unambiguous with respect to their terms, rejecting Reach’s argument that the "must ship by" dates were simply aspirational. The court also held that the evidence presented at trial was sufficient to prove Newsert's lost profits with reasonable certainty, dismissing Reach's argument that the losses were speculative and didn't account for overhead. Lastly, the court allowed the admission of evidence of prior criminal convictions of Reach’s Vice President for impeachment purposes, as the crimes involved fraud and deceit and were thus relevant to the issues in the case. View "Reach Companies, LLC v. Newsert, LLC" on Justia Law
Johnston v. Flying S Title & Escrow, Inc.
In a dispute arising from a failed subdivision in Missoula County, Montana, a group of property purchasers, led by Gilbert and Judith Johnston, claimed that Flying S Title and Escrow, Inc., breached a purported contract to provide title insurance for the properties they bought. The properties were originally platted as lots, but the purchasers believed that they would eventually be reconfigured into larger parcels. However, the necessary infrastructure was not installed and the amended plat was never recorded, so the parcels never came into existence. The purchasers claimed that pro forma documents provided by Flying S constituted a contract to insure the parcels. The Supreme Court of Montana disagreed, ruling that the pro forma documents did not constitute a contract, but were merely an offer to issue a title insurance policy for the parcels, subject to the terms stated in the documents. The court noted that a contract for title insurance could not exist under the pro forma documents because the parcels, and the title thereto, never existed. Furthermore, the court found that Flying S had not been unjustly enriched by the purchasers' premium payments because it had provided, as agreed, title insurance for the transaction completed by the purchasers to buy the lots. Therefore, the court affirmed the lower court's decision in favor of Flying S Title and Escrow, Inc. View "Johnston v. Flying S Title & Escrow, Inc." on Justia Law
Jiajing (Beijing) Tourism Co. Ltd. v. AeroBalloon USA, Inc.
In this case, decided by the United States Court of Appeals for the First Circuit, the dispute involved Aeroballoon USA, Inc., and its owner Douglas Hase (collectively, Aeroballoon/Hase), and Jiajing (Beijing) Tourism Co., Ltd. (Jiajing). In 2016, Jiajing contracted Aeroballoon for two tethered helium balloons at a total price of $1.8 million. Despite Jiajing making regular payments totaling $1,018,940, Aeroballoon failed to deliver the balloons. An arbitration panel awarded Jiajing $1,410,739.01 plus interest for Aeroballoon's breach of contract. Following the award, Hase dissolved Aeroballoon and Jiajing subsequently filed a complaint seeking enforcement of the arbitration award.The case focused on two counts: fraudulent transfers in violation of the Massachusetts Uniform Fraudulent Transfer Act (UFTA) and unfair business practices under Chapter 93A of the Massachusetts General Laws. The jury awarded Jiajing $1.6 million for each count. The district court later reduced the damages to $1.113 million for each count, a decision unchallenged by either party.The Court of Appeals affirmed the lower court's decision. The court held that the evidence was sufficient to support a finding that Aeroballoon had engaged in fraudulent transfers of at least $1.113 million. The court further held that even a single fraudulent transfer is sufficient to create liability under Chapter 93A, thereby affirming the verdict on the claim of unfair business practices. The court also awarded costs to Jiajing. View "Jiajing (Beijing) Tourism Co. Ltd. v. AeroBalloon USA, Inc." on Justia Law
Millard v. Talburt
This case involved a property dispute between neighbors Robert and Debra Talburt and Miles and Leanne Millard in Idaho. The Millards sought to establish their rights to a disputed tract of land and two easements, as well as breach of contract damages for maintenance of a shared well. The Talburts countered by constructing a fence within the roadway easement, stating they were relocating the roadway easement, and locking the pump house for the shared well. The Supreme Court of Idaho affirmed the district court's judgement in favor of the Millards on their claims related to the easements and ordered the Talburts to remove the fence and cease efforts to block access to the shared well. The court also found the Talburts' attempt to relocate the roadway easement to be unlawful, invalid, and void. However, the district court found that the Millards had abandoned their breach of contract claim and failed to establish a right to the disputed property. The Supreme Court also affirmed the district court's award of a portion of the Millards' attorney fees and costs to them. View "Millard v. Talburt" on Justia Law
Jones v. Solgen Construction
In the case of Maryann Jones v. Solgen Construction, LLC and GoodLeap, LLC, the Court of Appeal of the State of California Fifth Appellate District affirmed the trial court's decision not to compel arbitration. The case concerned a business relationship involving the installation of home solar panels. The appellants, Solgen Construction and GoodLeap, had appealed the trial court's denial of their separate motions to compel arbitration, arguing that the court had erred in several ways, including by concluding that no valid agreement to arbitrate existed.Jones, the respondent, had filed a lawsuit alleging fraudulent misrepresentation, fraudulent concealment, negligence, and violations of various consumer protection laws. She contended that she had been misled into believing she was signing up for a free government program to lower her energy costs, not entering into a 25-year loan agreement for solar panels. The appellants argued that Jones had signed contracts containing arbitration clauses, but the court found that the appellants had failed to meet their burden of demonstrating the existence of a valid arbitration agreement. The court also held that the contract was unenforceable due to being unconscionable.The appellate court affirmed the trial court's decision, rejecting the appellants' arguments that an evidentiary hearing should have been held and that the court had erred in its interpretation of the evidence and the law. It found that the trial court had not abused its discretion and that its finding that the appellants failed to meet their burden of proof was not erroneous as a matter of law. View "Jones v. Solgen Construction" on Justia Law
Trindade v. Grove Services, Inc.
Paulo Trindade, a former employee of Grove Services, Inc., sued his previous employer for breach of contract and violations of the Massachusetts Wage Act, claiming he had been underpaid on his sales commission compensation for the years 2014, 2015, and 2016. Following a bench trial, the United States District Court for the District of Massachusetts ruled in part for Trindade and in part for Grove, awarding Trindade $330,597 in damages. Both parties appealed. The United States Court of Appeals for the First Circuit affirmed the lower court's judgment. The Court of Appeals agreed with the district court's conclusion that Trindade's amended complaint, which included a claim for unpaid wages for 2016, related back to his original complaint, making the claim timely under Massachusetts law. The Court of Appeals also concluded that the district court was correct in its decision to award the damages it did, including an amount for the late payment and underpayment of Trindade's 2016 commission. View "Trindade v. Grove Services, Inc." on Justia Law