Justia Contracts Opinion Summaries
Kelly v. Kelly
Brandon and Brandi Kelly married on April 20, 2015, and had a child on June 9, 2015. Brandon filed for divorce on May 30, 2017. This appeal primarily concerned their disputes regarding the division of property and attorney fees. Prior to marriage, Brandon and Brandi entered into a prenuptial agreement (“the PNA”) seeking to establish their rights to various items of property. Brandi and Brandon were represented by separate counsel during the negotiation and execution of the PNA. Before signing the PNA, Brandi reviewed Brandon’s 2014 tax return. Brandi’s attorney requested changes to the PNA’s definitions of separate and community property, which were made. Brandi expressly waived her right to review other financial documentation concerning Brandon’s assets and signed the PNA. During the pendency of the divorce action, and relevant to this appeal, Brandon filed four motions for partial summary judgment and Brandi filed two motions for partial summary judgment, each of which required interpretation of various provisions of the PNA. After review, the Idaho Supreme Court affirmed in part, and reversed in part, certain district court decisions with respect to the parties' PNA. The Supreme Court found the district court erred (1) in affirming the magistrate court’s decision that the PNA barred Brandi from requesting attorney fees for child custody, visitation and support matters; (2) in affirming the magistrate court’s summary judgment decision concluding that Brandon’s payments from EIRMC were his separate property; and (3) when it failed to vacate the award of attorney fees to Brandon for his contempt motions, but did not err when it affirmed the magistrate court’s other deductions from Brandi’s separate property award. View "Kelly v. Kelly" on Justia Law
Nitkewicz v. Lincoln Life & Annuity Co. of N.Y.
The United States District Court for the Southern District Court concluded that Lincoln Life & Annuity Company of New York was not obligated under New York Insurance Law Section 3203(a)(2) to refund a payment that Plaintiff had deposited into a policy account associated with her life insurance policy five months before she died. Because no New York court has analyzed this provision of New York insurance law, and because insurance policy implicates significant New York State interests, the Second Circuit deferred a decision on this appeal in order to certify the following question to the New York Court of Appeals: Whether a planned payment into an interest-bearing policy account, as part of a universal life insurance policy, constitutes a “premium actually paid for View "Nitkewicz v. Lincoln Life & Annuity Co. of N.Y." on Justia Law
Huntington Ingalls Industries, Inc. et al. v. Ace American Insurance Company et al.
Insured Huntington Ingalls Industries, Inc. and insurer Huntington Ingalls Industries Risk Management LLC seek a declaratory judgment stating there is coverage under a property insurance policy for certain losses incurred by Huntington Ingalls Industries due to the COVID-19 pandemic. The trial court concluded that the complaint did not allege facts that would trigger coverage under the policy and granted judgment on the pleadings in favor of reinsurers. After review, the Vermont Supreme Court disagreed, reversed the trial court. and remanded for further proceedings. View "Huntington Ingalls Industries, Inc. et al. v. Ace American Insurance Company et al." on Justia Law
In re Ayad
The Supreme Court conditionally granted relief in this mandamus proceeding concerning a premarital agreement to resolve disputes by binding arbitration under religious law, holding that the trial court erred by ordering arbitration before determining whether the agreement was valid and enforceable, as required by Tex. Fam. Code 6.6015 and 153.00715.In 2008 the parties married. In connection with their marriage, they signed a document entitled "Islamic Pre-Nuptial Agreement" providing that conflicts arising between the parties would be resolved according to Islamic law in a Muslim court or a three-person panel. After Wife sued for divorce, Husband moved to enforce the agreement. The trial court stayed proceedings pending arbitration, and the court of appeals denied Wife's request for mandamus relief. The Supreme Court conditionally granted relief, holding that the trial court erred in ordering arbitration without first determining the validity and enforceability of the agreement. View "In re Ayad" on Justia Law
Kingery Construction Co. v. 6135 O Street Car Wash, LLC
The Supreme Court reversed the decision of the district court finding that Plaintiff did not waive its right to arbitration by its litigation-related conduct, holding that reversal was required in light of Morgan v. Sundance, Inc., __ U.S. __ (2022).Plaintiff sued Defendant for breach of contract. Defendant moved to dismiss the complaint with prejudice, arguing that Plaintiff waived its breach of contract claim under the parties' agreement by filing suit on the claim rather than commencing it in arbitration. Plaintiff subsequently filed a demand for arbitration and a motion to stay the case for arbitration. The district court granted Plaintiff's motion to stay the case, concluding that Defendant suffered no prejudice because of Plaintiff's litigation-related conduct. The Supreme Court reversed, holding that prejudice is not required to prove a party waived its right to stay a court case pending arbitration under section 3 of the Federal Arbitration Act following the United States Supreme Court's decision in Morgan. View "Kingery Construction Co. v. 6135 O Street Car Wash, LLC" on Justia Law
XRI Investment Holdings LLC v. Holifield
In this opinion, the Court of Appeals suggested reconsidering the holding of CompoSecure, LLC v. CardUX, LLC (CompoSecure II), 206 A.3d 807 (Del. 2018), and permitting a court of equity to consider equitable defenses to a breach of contract claim even when the parties have used the word "void" to describe the consequence of contractual noncompliance.Defendant, a co-founder and member of XRI Investment Holdings LLC (XRI), formed GH Blue Holdings, LLC as a single-member LLC and then transferred all of his Class B units in XRI to Blue (the Blue Transfer). Defendant sought to comply with a provision in the LLC agreement that governed XRI's internal affairs that generally prohibited members from transferring their member interests by evoking an exception for a transfer to a "Permitted Transferee." XRI alleged that the Blue Transfer was void ab initio and never became effective, and Defendant responded that XRI's claim was barred by the equitable defense of acquiescence. The Court of Chancery held (1) there was no impediment to a defendant raising a defense of acquiescence in response to a legal claim; and (2) this decision sets out the rationale for a court to reconsider the holding in CompoSecure II so that the Delaware Supreme Court may consider it in connection with any appeal. View "XRI Investment Holdings LLC v. Holifield" on Justia Law
Adler & Sons v. Axis Surplus Ins Co
During the covid-19 pandemic, state and local authorities in Louisiana ordered nonessential businesses to close for a time. This required Plaintiff to temporarily shut his jewelry stores and event spaces in New Orleans. To recoup income lost during the closure, Plaintiff claimed reimbursement under his insurance policy’s coverage for “direct physical loss of or damage to” his property. Plaintiff’s insurer, Axis, denied the claim. Plaintiff sued Axis along with his insurance agent and broker. The district court dismissed Plaintiff’s claims, concluding that Plaintiff suffered no covered loss or damages and that his agent and broker violated no duty to advise Plaintiff about pandemic-related coverage. The Fifth Circuit affirmed. The court explained that what denied Plaintiff use of his property was the government’s closure orders. Such losses do not involve a “tangible alteration to, injury to, or deprivation of property.” The district court therefore correctly dismissed Plaintiff’s claims against Axis. Further, contrary to Plaintiff’s arguments, what creates a Louisiana insurance agent’s duty to procure particular coverage is not a “close relationship” with the insured but an insured’s “specific” request for “the type of insurance coverage . . . needed.” Here, Plaintiff did not allege he specifically requested pandemic-related coverage from either the wholesale broker or insurance agent, therefore Plaintiff’s claims against those Defendants were properly dismissed. View "Adler & Sons v. Axis Surplus Ins Co" on Justia Law
Moore v. Centrelake Medical Group, Inc.
Appellants are patients at medical facilities operated by respondent Centrelake Medical Group. In reliance on Centrelake’s allegedly false representations that it employed reasonable safeguards for patients’ personal identifying information (PII), Appellants entered into contracts with Centrelake. Appellants brought an action against Centrelake on behalf of themselves and a putative class of patients affected by a data breach. The complaint contained causes of action for breach of contract, negligence, and violations of the Unfair Competition Law (UCL). Centrelake demurred, arguing that Appellants had failed to adequately plead any cognizable injury and that their negligence claim was barred by the economic loss rule. Appellants opposed the demurrer. On appeal, Appellants contend the court erred in sustaining the demurrer with respect to each of their claims and abused its discretion in denying their request for leave to amend. The Second Appellate District affirmed the judgment with respect to the dismissal of Appellants’ negligence claim without leave to amend, but reverse with respect to Appellants’ UCL and contract claims. The court concluded that Appellants adequately alleged UCL standing and contract damages under their benefit-of-the-bargain theory, and the Appellant who purchased monitoring services, did the same under Appellants’ monitoring-costs theory. However, Appellants have not shown the court erred in dismissing their negligence claim under the economic loss rule; nor have they shown the court abused its discretion in denying their request for leave to amend. View "Moore v. Centrelake Medical Group, Inc." on Justia Law
Dietzel Enterprises, Inc. v. J. A. Wever Construction, LLC
The Supreme Court affirmed in part and reversed in part the judgment of the district court finding that Dietzel Enterprises, Inc. (Dietzel) was the first party to materially breach a contract between Dietzel and J.A. Wever Construction, LLC and awarding Wever damages, holding that the evidence did not support the entirety of the damages awarded to Wever.Wever contracted with Dietzel to perform excavation work for the construction of a transmission line, but Dietzel eventually abandoned the project before work was completed. Dietzel brought this action asserting various claims, and Wever counterclaimed for breach of contract. The district court awarded judgment in favor of Wever. The Supreme Court reversed in part, holding (1) the evidence in the record did not support the entirety of the court's damages award; and (2) the district court did not otherwise err. View "Dietzel Enterprises, Inc. v. J. A. Wever Construction, LLC" on Justia Law
AV Automotive, LLC v. Gebreyessus
The Supreme Court affirmed in part and reversed and remanded in part the judgment of the circuit court awarding sanctions against Plaintiffs, holding that the circuit court erred in awarding the total amount of the attorney's fees claimed.Plaintiffs brought this claim alleging fraud, breach of fiduciary duty, tortious interference with a contractual relationship or business expectancy, and business conspiracy against Defendant, a former employee. After the circuit court granted Plaintiffs' motions to nonsuit as to all parties the circuit court granted Defendant's motion for sanctions, awarding sanctions of $213,197 - Defendant's total attorney's fees - against Plaintiffs. The Supreme Court reversed in part, holding that the circuit court (1) was within its discretion to award sanctions against Plaintiffs; but (2) erred in awarding sanctions for certain conduct and in failing to segregate sanctionable claim from the attorney's fees requested. View "AV Automotive, LLC v. Gebreyessus" on Justia Law