Justia Contracts Opinion Summaries

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The Supreme Court reversed the order of the district court granting summary judgment in favor of the cities of Pella and Oskaloosa regarding the validity of an agreement between the cities and Mahaska County to establish a regional airport authority, holding that Landowners had standing to challenge the agreement.Landowners brought this action seeking a judgment that the agreement at issue was illegal and an injunction to prevent the transaction. The district court held that Landowners lacked standing to bring the suit and granted summary judgment in favor of the Cities. The Supreme Court reversed, holding (1) by entering into the agreement, the County's Board of Supervisors bound future board to a particular course of legislative action, in violation of the Iowa Constitution; (2) the agreement violated precedent regarding delegation of a municipality's legislative power; and (3) therefore, the district court erred in declaring the agreement to be valid and ordering specific performance by the County of its obligations under the agreement. View "Site A Landowners v. South Central Regional Airport Agency" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment entered by the district court in this action involving former co-counsel on a contingent-fee case, holding that the district court erred in finding insufficient evidence that the Hope Law Firm's new entity, Hope Law Firm & Associates, P.C., was a successor entity to Hope Law Firm, P.L.C.Lawyer James Larew had an of-counsel arrangement with the Hope Law Firm and agreed to work on a particular client's case in exchange for a portion of the firm's fee. Larew and the firm later ended the of-counsel arrangement, and Larew ultimately won a large judgment at trial. This litigation concerned the disposition of the fee. On appeal, Larew appealed the district court's determination on the terms of an implied-in-fact contract, quantum meruit calculation, successor liability, and other causes of action. The Supreme Court reversed the district court's ruling as to successor liability and otherwise affirmed, holding that Larew showed that Hope Law Firm & Associates, P.C. was a successor entity to Hope Law Firm, P.L.C. View "Larew v. Hope Law Firm, P.L.C." on Justia Law

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The Supreme Court reversed the order of the circuit court disqualifying Stephen Goldman from further participation as the counsel of The Travelers Indemnity Company in a suit filed by the Board of Trustees of the University of Arkansas, holding that the circuit court abused its discretion.The Board, acting on behalf of the University of Arkansas for Arkansas System, brought this complaint against Travelers for breach of contract, declaratory judgment, and bad faith, alleging that it was entitled to benefits under its all-risk commercial insurance policy for damages it suffered during the coronavirus pandemic. After the circuit court entered its ruling disqualifying Goldman, a nonresident attorney, from further representing Travelers in this case Goldman and Travelers (together, Appellants) appealed, arguing that the circuit court erred by revoking Goldman's motion for admission pro hac vice. The Supreme Court agreed and reversed in part, holding that the circuit court's revocation of Goldman's pro hac vice status without prior notice or a reasonable opportunity to be heard violated due process requirements. View "Travelers Indemnity Co. v. Board of trustees of University of Ark." on Justia Law

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The Supreme Court affirmed the judgment of the circuit court certifying this class action against an auto insurance company brought by Plaintiffs, insureds who incurred medical expenses because of car accidents, holding that the circuit court did not abuse its discretion in concluding that the prerequisites of a class action had been satisfied.Instead of paying Plaintiffs for the full amount of billed medical expenses Defendant instead simply reimbursed them for the actual amount they owed their medical providers after all discounts had been applied. Plaintiffs brought this action that this practice constituted breach of contract and unjust enrichment. The court certified a class action, from which Defendant appealed. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion when it certified this case as a class action. View "Shelter Mutual Insurance Co. v. Baggett" on Justia Law

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Plaintiff Bainbridge Fund Ltd. is the beneficial owner of bonds issued by the Republic of Argentina. Argentina defaulted on these bonds back in 2001, but Bainbridge didn’t sue to recover them until 2016. The district court dismissed Bainbridge’s claims as untimely under New York’s six-year statute of limitations for contract actions and the Second Circuit’s nonprecedential decisions. Bainbridge appealed, asking the Second Circuit to reconsider those decisions. Specifically, Bainbridge argues that (1) the twenty-year statute of limitations for recovery on certain bonds under N.Y. C.P.L.R. 34 Section 211(a) applies to its claims against Argentina; and (2) even if the six-year limitations period for contract actions applies, it was tolled under N.Y. Gen. Oblig Law Section 17-101 because Argentina “acknowledged” this debt when it publicly listed the bonds in its quarterly financial statements (the “Quarterly Reports”).   The Second Circuit rejected Plaintiff’s arguments. First, the twenty-year statute of limitations does not apply to claims on Argentine bonds because a foreign sovereign is not a “person” under N.Y. C.P.L.R. Section 211(a). Second, tolling under N.Y. Gen. Oblig. Law Section 17-101 is inapplicable because the Quarterly Reports did not “acknowledge” the debt at issue in a way that reflected an intention to pay or seek to influence the bondholders’ behavior. To the contrary, Argentina repeatedly stated that the bonds “may remain in default indefinitely.” Bainbridge’s claims are thus time-barred. View "Bainbridge Fund Ltd. v. The Republic of Argentina" on Justia Law

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The Supreme Court affirmed the order of the district court granting a motion to approve a settlement agreement reached in mediation involving siblings Lily Smith and Sam, Dan, and Vernon Lindemulder, holding that Petitioners were not entitled to relief on their claims of error.The agreement at issue resolved claims involving the Alice M. Lindemulder Trust, established by the parties' mother, which held more than 2,000 acres of land in Stillwater County. Sam appealed the district court's decision to approve the settlement agreement, arguing that the agreement was unenforceable because he lacked the capacity to enter it and had been subjected to undue influence. The Supreme Court affirmed, holding that the district court (1) did not err in concluding that Sam validly consented to the agreement; and (2) did not err in holding that the agreement was valid and enforceable. View "Smith v. Lindemulder" on Justia Law

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The First Circuit affirmed the judgment of the district court entering summary judgment in favor of Defendant Thomas Wakefield and dismissing Plaintiff Pleasantdale Condominiums LLC's claims alleging nondisclosure of material information under a Maine statute, holding that Defendant was entitled to summary judgment as a matter of law.After it purchased an apartment complex Plaintiff sued Defendant, the seller, alleging claims for fraud and negligent misrepresentation. Both counts were based on the alleged violation of Me. Rev. Stat. Ann. tit. 33, 173(5). The district court concluded that Defendant was entitled to summary judgment on both counts. The First Circuit affirmed, holding that Defendant was entitled to summary judgment as a matter of law on Plaintiff's claim for fraud in the nature of active concealment. View "Pleasantdale Condominiums, LLC v. Wakefield" on Justia Law

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Warren Averett Companies, LLC, sought a writ of mandamus to direct a circuit court to vacate its order denying Warren Averett's motion to strike the jury demand asserted by Gerriann Fagan and to enter an order granting the motion to strike the jury demand. The underlying dispute involved a business proposition Warren Averett made to Fagan to to build a human-resources consulting practice. Fagan would wind down the operations of her company, The Prism Group; Fagan would then become a member of Warren Averett, and Warren Averett would purchase The Prism Group's equipment and furniture, assume responsibility for The Prism Group's leases; and that Warren Averett would assume The Prism Group's membership in Career Partners International, LLC. The "Standard Personal Service Agreement" ("the PSA") entered into by Fagan and Warren Averett drafted by Warren Averett included, in pertinent part, a dispute-resolution clause. Fagan resigned from Warren Averett after a salary dispute, and, on February 28, 2019, Fagan filed a demand for arbitration with the American Arbitration Association ("AAA"). The AAA determined that, under its rules, Fagan owed $300 and Warren Averett owed $1,900. The AAA also stated that any dispute regarding the filing fees should be raised before the arbitrator for a determination once all the filing requirements, including payment of the fees, had been satisfied. Warren Averett refused to pay its share of the filing fees as requested by the AAA, and the AAA closed the file in the matter. Thereafter, Fagan sued Warren Averett alleging multiple causes of action. Fagan demanded a jury trial. Warren Averett moved to dismiss the claims, and concurrently moved to compel arbitration. The Alabama Supreme Court determined Fagan did not show prejudice by the almost two-year delay between the filing of Fagan's amended complaint and the filing of Warren Averett's motion to strike the jury demand: "The trial court granted Warren Averett's motion to compel arbitration, and Fagan sought review of that decision. We reversed that decision; on remand, the trial court set a scheduling conference, and Warren Averett filed its motion to strike Fagan's jury demand. Although there was a delay between the time that Fagan demanded a jury and the time that Warren Averett sought to strike that demand, Fagan has not shown that she was prejudiced by that passage of time." Warren Averett's petition was granted and the writ issued. View "Ex parte Warren Averett Companies, LLC." on Justia Law

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The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to dismiss for lack of personal jurisdiction this breach of contract matter, holding that the trial court did not err in denying Defendant's motion to dismiss for lack of personal jurisdiction.Plaintiff, which was based in Durham, North Carolina, brought this action against Defendant, a California company, after Defendant allegedly refused to pay certain fees as required by the parties' agreement and terminated the agreement without cause. The trial court denied Defendant's motion to dismiss for lack of jurisdiction, concluding that Defendant had the requisite minimum contacts with the forum. The Supreme Court affirmed, holding that the maintenance of this suit did not offend traditional notions of fair play and substantial justice. View "Toshiba Global Commerce Solutions, Inc. v. Smart & Final Stores LLC" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the order of the district court concluding that Plaintiff was entitled to "reasonable attorney's fees" on appeal from a decision of the magistrate in Plaintiff's favor, holding that there was no error.The trial court awarded the attorney's fees at issue in this action seeking the recovery of money Defendant owed Plaintiff under a contract to purchase real estate that obligated Defendant, the buyer, to pay Plaintiff, the seller, a due diligence fee and an earnest money deposit. The court of appeals affirmed the attorney's fee award. The Supreme Court affirmed, holding that Defendant's allegations of error were unavailing. View "Reynolds-Douglass v. Terhark" on Justia Law