The Supreme Court affirmed the order of the circuit court appointing a special commissioner to execute a reformation deed consummating the parties' confidential settlement agreement and mutual release (the agreement) and dismissing the action, holding that the circuit court did not err.In dismissing this action, the circuit court found (1) Defendants' failure timely to release the notice of lis pendens in connection with the action, as required under the agreement, did not constitute a material "first breach" of the agreement; (2) Defendants did not waive their right to enforcement of the agreement's terms; and (3) the agreement and its extensions were neither procedurally nor substantively unconscionable. The Supreme Court affirmed, holding that the circuit court did not err in (1) enforcing the agreement and its extensions by appointing the special commissioner to execute a reformation deed under the agreement's terms; and (2) dismissing the action in its entirety. View "Triple 7 Commodities, Inc. v. High Country Mining, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeals with respect to Plaintiff's constitutional claims, holding that a state university's dismissal of a student for poor academic performance does not implicate a liberty or property interest protected by the Texas Constitution's guarantee of due course of law.Plaintiff was dismissed from Texas Southern University's Thurgood Marshall School of Law after one year due to his failure to maintain the required grade point average. Plaintiff brought this suit against the School, alleging breach of contract and deprivation of his property and liberty without due course of law. The trial court granted the School's plea to the jurisdiction invoking sovereign immunity. The court of appeals reversed in part, concluding that Plaintiff's procedural and substantive due course of law claims were viable. The Supreme Court reversed in part and rendered judgment dismissing the case, holding that an academic dismissal from higher education does not implicate a protected liberty interest. View "Texas Southern University v. Villarreal" on Justia Law

The Estate of Frances Elaine Warren entered into a purchase and sale agreement with Tricore Investments, LLC involving real property near Priest Lake in Bonner County, Idaho. Before closing, the Estate sold the property to other buyers: John Stockton and Todd Brinkmeyer. Tricore filed a complaint against the Estate for breach of contract and violation of the Idaho Consumer Protection Act (“ICPA”), among other things, and sought specific performance of the purchase and sale agreement. The complaint also alleged that Stockton and Brinkmeyer tortiously interfered with the purchase and sale agreement and that the Estate, Stockton, and Brinkmeyer (collectively, “Appellants”) engaged in a civil conspiracy. The case proceeded to a bench trial where the district court found: (1) the purchase and sale agreement between the Estate and Tricore constituted a valid and enforceable contract; (2) the Estate breached the contract when it sold the property to Stockton and Brinkmeyer; (3) the Estate’s actions violated the ICPA; (4) Stockton and Brinkmeyer tortiously interfered with the contract; and (5) Appellants engaged in a civil conspiracy. The district court ordered specific performance of the contract but declined to award any additional damages. The Estate and Stockton jointly appealed; Brinkmeyer appealed separately. The Estate argued the purchase and sale agreement was not a valid, enforceable contract because it violated the statute of frauds and there was no meeting of the minds. In the alternative, the Estate argued it did not breach the contract because Tricore repudiated it, and it did not violate the ICPA. Stockton and Brinkmeyer argued they did not tortiously interfere with the purchase and sale agreement. Together, Appellants argued they did not engage in a civil conspiracy. The Idaho Supreme Court affirmed the district court’s grant of summary judgment for Tricore on the Estate’s statute of frauds defense. The Court also affirmed the district court's findings that: (1) the Estate breached the Tricore PSA; (2) the Estate violated the ICPA; and (3) Stockton and Brinkmeyer tortiously interfered with the Tricore PSA. The district court's finding that Appellants engaged in a civil conspiracy was reversed. As a result, the attorney fee award was affirmed only as it applied to the Estate from fees against Stockton and Brinkmeyer. Tricore was not entitled to monetary damages on the tortious interference claim. View "Tricore Investments LLC v. Estate of Warren" on Justia Law

The Supreme Judicial Court vacated the portion of the trial court's judgment denying Plaintiff's claim under Mass. Gen. Laws ch. 93A, 11 and affirmed the remainder of the judgment, holding that the judge erred in instructing the jury under section 11.The attorney defendants in this case misappropriated propriety materials from their employer during their employment and subsequently used those materials to compete with their former employer. A jury found Defendants liable on claims for conversion, conspiracy, and breach of the duty of loyalty. The jury denied relief on the plaintiff employer's claims for unfair or deceptive trade practices, in violation of section 11. The Supreme Judicial Court vacated the judgment in part, holding that Defendants may be liable for unfair or deceptive trade practices, and the judge erred in instructing the jury that Defendants' conduct before leaving their employer was not relevant to Plaintiff's claim under section 11. View "Governo Law Firm LLC v. Bergeron" on Justia Law

In this contract dispute involving the correct interpretation of a mineral lease's "continuous drilling program" provision the Supreme Court held that the court of appeals erred in reversing partial summary judgment for the lessee on the contract-construction issue.Lessor and Lessee were the successors-in-interest to an oil-and-gas top lease covering a 30,450-acre parcel of land. At the end of the primary term, Lessee was required to reassign to Lessor all of Lessee's operating rights in each tract of the lease not then held by production unless Lessee was engaged in a "continuous drilling program." Notwithstanding Lessee's continued drilling operations, Lessor filed a suit seeking a declaration that the lease had terminated. The trial court granted partial summary judgment for Lessor, concluding that the lease had not terminated as to non-producing tracts. The court of appeals reversed. The Supreme Court reversed, holding (1) under the lease's special definition of drilling operations, activities other than spudding-in a well are sufficient to maintain the lease as to non-producing tracts; and (2) the record conclusively established that Lessee was engaged in a continuous drilling program within the meaning of the lease. View "Sundown Energy LP v. HJSA No. 3" on Justia Law

After a jury found that the manufacturer breached its duty to sell its products to certain customers exclusively through the distributor, the manufacturer appealed the denial of a directed verdict as to the status of two customers under the contract. The distributor cross-appealed a ruling that invalidated the contract's liquidated-damages clause and a ruling that prevented it from pursuing lost-profit damages.The Eleventh Circuit concluded that, under Federal Rule of Civil Procedure 6, the closure of the clerk's office renders the office inaccessible and tolls the filing deadline, which makes the motion timely. Therefore, the district court did not err in denying the manufacturer's Federal Rule of Civil Procedure 50 motions. The court also concluded that the district court did not err when it ruled that the liquidated-damages clause was unenforceable because $2 million a breach was grossly disproportionate to the foreseeable actual damages, and the disproportionality amounts to an unenforceable penalty. The court further concluded that the district court did not abuse its discretion by excluding lost-profit damages because Circuitronix failed to disclose its computation of those damages. View "Circuitronix, LLC v. Kinwong Electronic (Hong Kong) Co., Ltd." on Justia Law

In this appeal arising from a contract action, the First Circuit affirmed the judgment of the district court denying Appellants' post-trial request for a declaratory judgment, holding that the district court did not abuse its discretion.Appellants, Covidien LP and Covidien Holding Inc. (collectively Covidien), brought this action against Brady Esche, a former employee, who assigned medical device patent rights to a company he subsequently founded, seeking declaratory judgment to the effect that Esch assign his rights, title, and interest in the patent applications to Covidien. Covidien also alleged that Esch breached his obligations under employment and/or separation agreements he signed. The jury found that Esch breached confidential information and awarded Covidien damages. Covidien subsequently moved for a declaratory judgment asking that Esch be required to assign to Covidien the inventions he subsequently made. The district court denied the request. The First Circuit affirmed, holding that the district court did not abuse its discretion in denying Appellants' post-trial declaratory judgment request. View "Covidien LP v. Esch" on Justia Law

In 2014, the Rowlands first met with Morris (SMF), for financial planning advice. In 2015, Morris sold them two annuity contracts; in 2016, Morris sold them universal life insurance. In 2017, the Rowlands hired Morris to manage their investment accounts and completed SMF’s Asset Management Agreement (AMA) and new account forms from TD Ameritrade, which were bundled into a single, 54-page pdf. The Rowlands signed the forms using the online platform, “DocuSign.” The AMA included an arbitration section. Right above the signature block, the contract included this disclaimer, bolded and in all capital letters: “This Agreement contains a pre-dispute arbitration clause.”The Rowlands filed suit, alleging contract and fraud claims. The parties submitted different versions of the AMA to the court for its decision on SMF’s motion to compel arbitration. The district court found that the parties had not formed an agreement to arbitrate. The Fourth Circuit affirmed. Under the Federal Arbitration Act, courts determine whether a contract has been formed. Here, there was no meeting of the minds. The versions of the AMA signed by the Rowlands and by SMF’s agent contained materially different terms. View "Rowland v. Sandy Morris Financial LLC" on Justia Law

The Supreme Court dismissed this appeal for want of jurisdiction, holding that no final order had been entered in this matter.The co-personal representatives of the Estate of Gale S. Iverson sued Cheri Eaton, Iverson's former caretaker, seeking to recover property that the Estate alleged Eaton unlawfully transferred to herself. The Estate requested that Eaton be ordered to provide the Estate an accounting. Eaton, in turn, sued the Estate in a separate action for breach of express and implied contract and quantum meruit. The district court consolidated the actions, denied Eaton's claims, and ordered that Eaton provide the Estate an accounting. Eaton appealed. The Supreme Court dismissed the appeal for want of jurisdiction, holding that no final order had been entered in this matter. View "Davidson-Eaton v. Iversen" on Justia Law

The Supreme Court affirmed the judgment of the superior court denying Defendant's renewed motion for judgment as a matter of law or, in the alternative, a motion for a new trial, holding that the trial justice did not err in denying the motions.A dispute over certain real property resulted in litigation and a jury trial. Plaintiff bought an eight-count amended complaint against Defendant. The jury was instructed to consider only Plaintiff's promissory estoppel and unjust enrichment claims, and the jury rendered a verdict in favor of Plaintiff on those counts. The Supreme Court affirmed, holding that Defendant was not entitled to judgment as a matter of law or a new trial as to the promissory estoppel and unjust enrichment claims. View "Salvatore v. Palangio" on Justia Law