Justia Contracts Opinion Summaries
Miller v. Wesbanco Bank, Inc.
In these consolidated appeals arising from breach of contract litigation between Thomas and Jamie Miller and WesBanco Bank, Inc., the Supreme Court affirmed the circuit court's denial of prejudgment interest to the Millers and reversed the jury's damages award, holding that the Millers' evidence failed to support this verdict.On appeal, the Millers, who prevailed below, challenged the denial of their request for prejudgment interest, which was based upon their failure to request prejudgment interest from the jury. In its separate appeal, WesBanco raised four assignments of error. The Supreme Court remanded in part for further proceedings, holding (1) there was no error in the circuit court's denial of prejudgment interest; (2) there was no error in the admission of parol evidence; (3) the duty of good faith and fair dealing was properly applied to modify WesBanco's contractual obligations; (4) the circuit court did not err in denying judgment as a matter of law to WesBanco; and (5) the jury's damages award of $404,500 was against the clear weight of the evidence. View "Miller v. Wesbanco Bank, Inc." on Justia Law
RMR Equipment Rental, Inc. v. Residential Fund 1347, LLC
Residential Fund entered a contract with RMR for RMR to supply Residential Funds' mobile home park with drinking water beyond what the wells could produce. The trial court subsequently found that the park breached the contract in 2015 but limited RMR's damages to three months, reasoning that the contract was terminable at will. RMR requested damages be calculated from breach to the date of trial, which was about four years.The Court of Appeal concluded that the trial court erred by awarding damages for three months only where the contract between the parties was a requirements contract that was not terminable at will. In this case, the contract had an express termination clause that the court must respect, and thus the trial court should have awarded damages for roughly four years. Accordingly, the court remanded for a calculation of an award based on this interval. View "RMR Equipment Rental, Inc. v. Residential Fund 1347, LLC" on Justia Law
BPX Operating Co v. Strickhausen
The Supreme Court affirmed the judgment of the court of appeals concluding that Petitioners (collectively, BPX) were not entitled to summary judgment on the issue of whether Margaret Strickhausen impliedly ratified an unauthorized pooling agreement, holding that BPX did not establish implied ratification as a matter of law.BPX was a lessee of Strickhausen's mineral interest. The lease required BPX to obtain Strickhausen's express written consent before pooling her tract with others. Strickhausen never gave express written consent to BPX, which meant that BPX could not pool "under any circumstances." Strickhausen sued BPX for breach of contract, among other claims, after BPX filed a certificate of pooling authority for a well on her tract. BPX filed a motion for summary judgment, arguing that Strickhausen impliedly ratified the pooling because she accepted royalty payments calculated on a pooled basis. The trial court granted an interlocutory summary judgment for BPX on Strickhausen's wrongful pooling, commingling, and failure to account claims. The court of appeals reversed. The Supreme Court affirmed, holding that summary judgment for BPX on the issue of implied ratification was improper. View "BPX Operating Co v. Strickhausen" on Justia Law
Colwell v. MCNA Insurance Co.
The Supreme Court affirmed the ruling of the district court against Defendant and in favor of Plaintiff finding breach of contract and breach of implied covenant of good faith and fair dealing, holding that the district court erred.Defendant, a managed care organization, entered into a contract with Plaintiff, a dentist, to deliver dental services to Medicaid participants as a member of Defendant's network. Defendant later sent Plaintiff a "notice of non-renewal" of the provider contract. Plaintiff sued, and the district court ruled that the provider contract did not allow Defendant to terminate Plaintiff through non-renewal of the provider contract. At issue was whether Defendant properly ended a provider contract that automatically renewed for successive one-year terms by sending a notice of non-renewal. The Supreme Court affirmed, holding that the district court correctly determined that Defendant possessed no right to terminate by non-renewal. View "Colwell v. MCNA Insurance Co." on Justia Law
People v. Bankers Insurance Co.
In August 2018, Surety posted a $100,000 bond for Lee's release from the San Mateo Jail. On September 13, Lee failed to appear at a scheduled preliminary hearing. The court issued a bench warrant and ordered the bail forfeited. On September 21, the clerk of the court mailed a “Notice of Order Forfeiting Bail” to Surety. On March 25, 2019, Surety moved to vacate the forfeiture and exonerate the bail. Supporting exhibits indicated that Lee was in custody in Alameda County on federal charges and that the San Mateo County District Attorney’s Office had been notified of that detention. Surety argued that the court was required to vacate the forfeiture and exonerate the bail under Penal Code 1305(c)(3) because Lee had been surrendered by the bail agent to local law enforcement agencies; if the district attorney were to choose not to extradite, exoneration of bail was required under section 1305(f); and if the district attorney were to place a hold on Lee, the court should exonerate bail under section 1305(i) and (c)(3). As alternative relief, Surety requested tolling urging that Lee was disabled from appearing in court. The District Attorney elected to extradite Lee.The trial court denied Surety’s motions. The court of appeal ordered the trial court to exonerate the bond, noting that it failed to timely enter summary judgment and now lacks jurisdiction to enforce the forfeiture. View "People v. Bankers Insurance Co." on Justia Law
S. Katzman Produce Inc. v. Yadid
Defendant appealed from so much of the district court's judgment that orders him, jointly and severally with his codefendants Orel, to pay plaintiffs, suppliers of perishable goods, a total of $606,664.87, including principal amounts totaling $473,268.82, plus interest and attorneys' fees, because Orel failed to pay plaintiffs for goods purchased, and because of the dissipation of the statutory trust imposed on Orel's assets for the benefit of unpaid suppliers, in violation of the Perishable Agricultural Commodities Act (PACA). The district court granted plaintiffs' motion for summary judgment holding defendant liable on the ground that he was a person in control of the trust assets.The Second Circuit concluded that partial summary judgment was appropriate with respect to $40,000 of PACA trust assets that were placed in defendant's personal bank account, but that whether he had the necessary degree of control over other assets could not be resolved as a matter of law. In this case, defendant was neither an owner nor an officer of Orel. Accordingly, the court vacated the judgment in part and remanded for trial on the issue of defendant's control over other Orel assets. View "S. Katzman Produce Inc. v. Yadid" on Justia Law
Page v. Meyers
The Supreme Court affirmed the decision of the district court granting summary judgment to Defendants and dismissing Plaintiff's claims for negligent misrepresentation and intentional interference with a contract, holding that Defendants were entitled to summary judgment.Plaintiff sued Defendants, her adult stepchildren, claiming that they caused their father - and Plaintiff's late husband - to remove Plaintiff as the primary beneficiary of his insurance plan. The district court determined that Plaintiff failed to present evidence to establish any genuine dispute of material fact for trial and awarded summary judgment for Defendants. The Supreme Court affirmed, holding that summary judgment was proper because Plaintiff failed to establish a dispute of material fact as to whether Defendants supplied false information and as to whether a valid contract existed between her and Defendants. View "Page v. Meyers" on Justia Law
Gem State Roofing, Incorp. v. United Components, Inc.
Beginning in the 1980s and 1990s, two Idaho businesses did roofing work under substantially similar names: one, Gem State Roofing, Inc., performed work primarily in Blaine County (Gem State-Blaine); the other was a corporation operating under the name Gem State Roofing and Asphalt Maintenance, which also did business as Gem State Roofing. The latter was based in Boise, Idaho, and performed work in a significantly larger area. In 2011, Gem State Roofing and Asphalt Maintenance was succeeded in interest by United Components, Inc. (UCI.) Notwithstanding its change of name, it continued to do business as Gem State Roofing. In 2005, prior to UCI’s name change, the two businesses with similar names entered into a Trademark Settlement Agreement (TSA), prohibiting UCI from advertising, soliciting, or performing business in Blaine County, with exceptions for certain services (i.e., warranty, maintenance work, or work performed for previous customers). In addition, UCI agreed that if it received a request for work it was contractually unable to fulfil because of the TSA, it would refer the work to Gem State-Blaine. In 2018, Gem State-Blaine sued UCI, alleging it had breached the TSA when it advertised, solicited, bid on, and performed roofing work in Blaine County, and had failed to refer requests for work as required under the TSA. After a bench trial, the district court concluded that, despite UCI’s breach of the TSA and the implied covenant of good faith and fair dealing, Gem State-Blaine had failed to prove damages or that it was entitled to a permanent injunction. The district court further found that Gem State-Blaine had no protectable common-law trademark. Finally, the district court concluded that there was no prevailing party and declined to award attorney fees and costs. Gem State-Blaine timely appealed. UCI timely cross-appealed the district court’s denial of its request for attorney fees and costs. After review, the Idaho Supreme Court reversed in part, affirmed in part, vacated in part, and remanded for further proceedings. The district court’s refusal to enter a permanent injunction was reversed, and the court directed to enter a permanent injunction to enjoin UCI from any further breach of the TSA. The district court’s refusal to award attorney fees and costs as a sanction for UCI’s discovery violations, and the district court’s conclusion that Gem State-Blaine did not have a protectable common-law trademark against UCI were also reversed. The Supreme Court vacated the district court’s determination that neither party prevailed. The matter was remanded for the district court to determine whether there was a prevailing party, and to determine if attorney fees and costs should be awarded. The district court’s decision denying damages was affirmed. View "Gem State Roofing, Incorp. v. United Components, Inc." on Justia Law
Poller v. Okoboji Classic Cars, LLC
The Supreme Court affirmed in part and reversed in part the judgment of the district court concluding that Plaintiffs were not entitled to relief on their contract claim and that Defendant was entitled to a verdict on its counterclaim for breach of contract, holding that judgment was improperly granted on Defendant's counterclaim.Plaintiffs, the owners of a 1931 Chevy, brought this lawsuit against Defendant, a company in the business of restoration of antique vehicles, arguing that Defendant violated certain provisions of the Motor Vehicle Service Trade Practices Act (MVSTPA), Iowa Code chapter 537B and breached its contract with Plaintiffs. Defendant filed a counterclaim alleging breach of contract. The district court concluded that there were no violations of the MVSTPA, that Plaintiffs were not entitled to relief on their contract claim, and that Defendant was entitled to damages on its counterclaim. The Supreme Court reversed the judgment in favor of Defendant on the counterclaim, holding that Defendant violated several provisions of Iowa Code chapter 537B and therefore may not seek to enforce the terms of a contract that was unlawfully formed, but Plaintiffs did not establish actual damages arising from the alleged damages. View "Poller v. Okoboji Classic Cars, LLC" on Justia Law
Christopherson v. American Strategic Insurance Co.
Two trees fell on Christopherson’s home, months apart, resulting in its total destruction. The village ordered demolition. Christopherson’s insurer, ASI, had advanced living expenses but did not provide the requested demolition payment by the village's deadline, so Christopherson razed the house himself. He did not provide invoices for the demolition or for his own labor. Christopherson sued, alleging bad-faith denial of policy benefits and informed ASI that, excluding personal property losses and additional living expenses yet to be determined, Christopherson’s losses were $143,384: the $135,000 dwelling coverage limit, $6,884 for demolition, and $1,500 for tree removal. ASI indicated that it would pay that amount, noting that it had not yet received any notice of claims for personal property.The court granted ASI a discovery protective order with respect to the bad faith claim, reasoning that Christopherson could not establish any underlying breach of the policies. ASI had already paid the full limits of his 2018–19 policy, Christopherson’s claims under his 2017–18 policy, and his additional living expenses under both policies. ASI obtained summary judgment. Christopherson had not presented evidence of costs actually incurred but not paid by ASI and could not show a breach; he had nearly exhausted the limits under both policies.The Seventh Circuit affirmed, rejecting an argument that the case should be remanded to state court. Christopherson’s arguments ignore policy provisions that the insured must first incur the expenses and then provide the insurer with documentation before the insurer is obliged to pay. View "Christopherson v. American Strategic Insurance Co." on Justia Law