The Supreme Court affirmed the order of the district court affirming the judgment of the Nebraska Department of Health and Human Services (DHHS) concluding that DHHS had overpaid OMNI Behavioral Health (OMNI) under a contract, holding that there was no merit to the errors assigned by OMNI.Under the contract at issue, OMNI agreed to operate a group home and provide services for individuals with developmental disabilities. In 2018, DHHS issued a notice of overpayment to OMNI determining that OMNI was overpaid under the contract by $34,876. After a hearing, hearing officer recommended that DHHS' finding of an overpayment be affirmed. The director of the Division of Developmental Disabilities adopted the hearing officer's order as the final order. The Supreme Court affirmed, holding that there was no merit to the errors assigned by OMNI. View "OMNI Behavioral Health v. State" on Justia Law

The Supreme Court reversed the trial court's grant of summary judgment in favor of Continental Western Insurance Company and dismissing G&G Oil Company of Indiana's claim for losses from a ransomware attack, holding that neither party demonstrated that it was entitled to summary judgment.G&G Oil purchased an insurance policy from Continental. One provision of the policy - the "Computer Fraud" provision - covered loss "resulting directly from the use of any computer to fraudulently cause a transfer of money." G&G Oil was the target of a ransomware attack and submitted a claim for coverage of its losses under the "Commercial Crime" provision of the policy. Continental denied the claim. G&G Oil then brought this complaint. The trial court granted summary judgment for Continental. The Supreme Court affirmed, holding that, although G&G Oil's losses "resulted directly from the use of a computer," neither party was entitled to summary judgment. View "G&G Oil Co. of Indiana v. Continental Western Insurance Co." on Justia Law

J.R. Simplot Company (“Simplot”) hired Erik Knudsen for a position as a packaging engineer. Early on in his employment, Knudsen was told that he would be the startup manager on a Simplot project in Grand Forks, North Dakota. Knudsen was unfamiliar with the startup manager position and questioned whether those job duties were fairly within the scope of his employment as a packaging engineer. Simplot and Knudsen disagreed as to the nature of his job, leading to the eventual termination of Knudsen’s employment. After his dismissal, Knudsen filed this action, alleging fraud, promissory estoppel, breach of the covenant of good faith and fair dealing, and negligent infliction of emotional distress. The district court granted Simplot’s motion for summary judgment as to all of Knudsen’s claims and denied Simplot’s subsequent motion for attorney’s fees. The Idaho Supreme Court determined Knudsen's fraud claim was cognizable notwithstanding the at-will employment doctrine. However, the Supreme Court concluded summary judgment on all of Knudsen's claims was appropriate. View "Knudsen v. J.R. Simplot Company" on Justia Law

After plaintiff purchased licenses for RCI non-thermal, pulverizing, and drying system technology (PAD), he alleged that the capabilities of the PAD System were misrepresented to him. Two federal law suits were filed, one in Iowa and one in Missouri.In this consolidated appeal, the Eighth Circuit affirmed the Iowa judgment, rejecting RCI's argument that it is entitled to judgment as a matter of law because the jury awarded no compensatory damages. The court concluded that punitive damages were recoverable under Iowa law because the jury necessarily found that plaintiff suffered actual damages when it found fraudulent misrepresentation. Furthermore, the jury could award punitive damages without an award of compensatory damages, and the punitive award was not unconstitutionally excessive. The court also concluded that plaintiff is not entitled to equitable relief and the district court neither erred or abused its discretion as to plaintiff's equitable counterclaims. Finally, the court found that the method used and reasons given by the district court for the reduction in costs were well within its discretion, and the district court did not abuse its discretion in awarding attorney fees.The court remanded the Missouri judgment for further proceedings, concluding that the district court erred by applying federal law, rather than Iowa law, to determine whether plaintiff's claim was precluded. The district court also erred by determining that Missouri law on the economic loss doctrine would bar plaintiff's misrepresentation claims. The court also noted that plaintiff's conspiracy claim should be reinstated and the district court's attorneys' fee award to Resource as the prevailing party is set aside. View "Dunne v. Resource Converting, LLC" on Justia Law

Dansko conducted due diligence to replace the trustee for its employee stock ownership plan. Benefit falsely denied having been recently been investigated by the Department of Labor. Dansko’s board passed a resolution appointing Benefit as the new trustee under the Trust Agreement. Around that time, Dansko decided to refinance its debt. Benefit never agreed in writing to help with the refinance but allegedly said it would “be able to do the [deal]” and estimated that it would need a month or more to do due diligence for the trust. Dansko thought Benefit would be the trustee for the deal. In December 2014, Benefit told Dansko that it would not serve as trustee for the debt deal, which delayed the deal and allegedly cost Dansko more than $2 million in extra interest.Dansko sued Benefit, alleging breach of the trust agreement, breach of an implied promise (promissory estoppel), and that Benefit fraudulently induced Dansko to hire it by falsely denying the DOL investigation. Benefit counterclaimed for its defense costs under an indemnification clause in the trust agreement. The district court rejected Dansko’s claims but held that Dansko did not have to indemnify Benefit for its defense costs. Applying Pennsylvania law, the Third Circuit vacated. The court erred in rejecting Dansko’s contract, estoppel, and fraud claims but under the trust agreement, Dansko must advance the trustee’s reasonable litigation expenses. View "Dansko Holdings Inc. v. Benefit Trust Co." on Justia Law

The underlying class action alleged that the Illinois Department of Corrections (IDOC) unlawfully denied hearing-impaired inmates “the assistance they need to communicate effectively and participate in IDOC programs and services.” A 2018 Settlement required IDOC to screen inmates for hearing problems, refer inmates in need to a licensed audiologist for a more thorough audiological evaluation, maintain records of inmates’ evaluations, and provide inmates with care according to the results of their evaluations. For about a year after the court approved the Settlement, IDOC incorrectly referred about 700 inmates to licensed hearing instrument dispensers (LHIDs)—hearing-aid salesmen—instead of audiologists for evaluations. IDOC discontinued the practice in July 2019, based on an out-of-court agreement.In 2020, Plaintiffs moved to enforce the Settlement arguing that IDOC is not ensuring that the audiological evaluations are completed within a reasonable time period and sought attorney fees for the investigation and resolution of the LHID violations. The district court concluded that IDOC was in substantial non-compliance with the Settlement through the LHID violations,, ordered IDOC to pay about $54,000 in attorney fees, and held that the Settlement requires IDOC to ensure the audiological evaluations are completed within a reasonable timeframe, which it defined as 90 days after a referral. The Seventh Circuit affirmed with respect to attorneys’ fees. The district court incorrectly determined that IDOC was obligated to ensure that its inmates receive audiological evaluations within a set timeframe; the Settlement contains no such requirement. View "Holmes v. Godinez" on Justia Law

The Supreme Court conditionally granted mandamus relief in this arbitration dispute, holding that the trial court abused its discretion in determining that pre-arbitration discovery was warranted in this case.After Plaintiff's employment was terminated she sued Defendant, her former employer, claiming discrimination and retaliation. Defendant moved to compel arbitration pursuant to the company's employee handbook acknowledgment and agreement, which contained an arbitration agreement. At issue was Plaintiff's second motion to compel pre-arbitration discovery claiming that an enforceable arbitration agreement did not exist. After the trial court granted the motion Defendant sought mandamus relief. The court of appeals denied the motion. The Supreme Court conditionally granted mandamus relief, holding that the trial court clearly abused its discretion in ordering pre-arbitration discovery because Plaintiff failed to provide the trial court with a reasonable basis to conclude that it lacked sufficient information to determine whether her claims were arbitrable. View "In re Copart, Inc." on Justia Law

The Supreme Court affirmed in part and reversed in part the trial court's decision resolving all issues in this oil and gas dispute favorably to the lessors of a mineral lease and awarding damages for underpayment of royalties, holding that remand was required to determine damages, if any, for off-premises compressor-fuel use.One lease provision in this case required the lessee to "compute and pay royalties on the gross value received." The other lease provision at issue required royalties to be "computed at the end of the mouth of the well." The Supreme Court affirmed the lower courts' judgments except as to the portion of the judgment awarding damages for royalties on compressor fuel, holding (1) the lower courts correctly concluded that the lessee's deduction of postproduction costs was in error because the mineral lease explicitly resolved the conflict in favor of a gross-proceeds calculation; and (2) because the compressor-fuel damages were not conclusively established in the amount awarded, remand was required. View "BlueStone Natural Resources II, LLC v. Randle" on Justia Law

The Supreme Court affirmed the decision of the district court granting Defendants' motion for summary judgment and dismissing Plaintiff's claims for negligent misrepresentation, fraudulent misrepresentation, and breach of contract, holding that Plaintiff's claims were subject to the two-year statute of limitations set forth in Iowa Code 614.1(9) and were untimely.On Defendants' motion for summary judgment, the district court held that Plaintiff's causes of action arose out of patient care and were barred by section 614.1(9), the two-year statute of limitations governing malpractice action. The Supreme Court affirmed, holding that each of Plaintiff's allegations originated from representations regarding patient care and the patient care Defendants provided, and therefore, Plaintiff's claims were untimely under section 614.1(9). View "Kostoglanis v. Yates" on Justia Law

The Supreme Court affirmed the ruling of the district court granting summary judgment in favor of a finance company in this contract dispute, holding that the contract was properly ratified despite any allegation of forgery.Natalya Rodionova Medical Care (NRMC) allegedly entered into a financing agreement with GreatAmerica Financial Services Corporation for the leasing of telephone and copier products. Pursuant to the agreement, NRMC made monthly payments totaling seven months worth of installments but then attempted to cancel the finance agreement. When NRMC discontinued further payments GreatAmerica sued for breach of contract and unjust enrichment. In its answer NRMC alleged that the finance agreement appeared to be signed by NRMC's sole shareholder but that the signature was a forgery. The district court granted summary judgment for GreatAmerica, reasoning that NRMC ratified the contract through its conduct regardless of who signed the contract. The Supreme Court affirmed, holding that NRMC's failure to reject goods over a seven-month period and its payment of periodic invoices amounted to a ratification. View "GreatAmerica Financial Services Corp. v. Natalya Rodionova Medical Care, P.C." on Justia Law