Teatotaller, LLC appealed a circuit court order dismissing its small claim complaint against the defendant Facebook, Inc. Teatotaller alleged that in June 2018, Facebook “deleted [Teatotaller’s] Instagram . . . account without notice.” Teatotaller further alleged that Facebook “sent two contradicting statements as to the reason for deletion and provided no appeal or contact to get more information.” Teatotaller alleged that Facebook “had a duty of care to protect [Teatotaller] from an algorithmic deletion as it hampers [Teatotaller’s] business” and that Teatotaller has “continue[d] to lose business and customers due to [Facebook’s] negligence.” In addition to seeking $9,999 in damages, Teatotaller sought restoration of its Instagram account. Facebook moved to dismiss, arguing Teatotaller's claims were barred under Section 230(C)(1) of the Communications Decency Act (CDA). Furthermore, Facebook argued Teatotaller's complaint failed to establish the New Hampshire trial court had personal jurisdiction over Facebook. Following a hearing, the trial court granted Facebook’s motion, determining that the Terms of Use gave the court personal jurisdiction over Facebook, but also precluded Teatotaller’s claims. The New Hampshire Supreme Court determined it was not clear on the face of Teatotaller’s complaint and objection whether prong two of the CDA immunity test was met, therefore the trial court erred by dismissing Teatotaller’s breach of contract claim on such grounds. The Court "simply cannot determine based upon the pleadings at this stage in the proceeding whether Facebook is immune from liability under section 230(c)(1) of the CDA on Teatotaller’s breach of contract claim." Though Teatotaller’s breach of contract claim could ultimately fail, either on the merits or under the CDA, the Supreme Court held that dismissal of the claim was not warranted at this time. View "Teatotaller, LLC v. Facebook, Inc." on Justia Law

Hess Bakken Investments II, LLC; Arkoma Drilling II, L.P.; and Comstock Oil & Gas, LP, (together the “Hess Group”) appealed an order and judgment dismissing their claims against AgriBank, FCB; Intervention Energy, LLC; and Riverbend Oil & Gas VI, L.L.C. (together, “Appellees”). At issue was the meaning of the term “actual drilling operations” as used in continuous drilling clauses in two oil and gas leases. The district court interpreted the term as requiring “placing the drill bit in the ground and penetrating the soil.” Each side has advanced competing readings of the term based on understandings of English grammar and industry usage. Although at odds, both interpretations are supported by rational arguments. The North Dakota Supreme Court concluded the term was ambiguous; "when ambiguity exists, the parties’ intent becomes a question of fact requiring a factual finding based on extrinsic evidence." Given this ambiguity, dismissal as a matter of law was improper. View "Hess Bakken Investments II, et al. v. AgriBank, et al." on Justia Law

The First Circuit reversed the district court's grant of summary judgment to TLS Management and Marketing Services, LLC (TLS) on its breach of contract claims against Ricky Rodriguez-Toledo, ASG Accounting Solutions Group, Inc. (ASG), and Global Outsourcing Services, LLC (GOS) and the court's finding that Rodriguez and ASG were liable for misappropriation of trade secrets, holding that TLS failed to prove its trade secret claims, and the nondisclosure agreements were unenforceable.Rodriguez was the founder of ASG, a company that, like TLS, offered services in tax planning. ASG signed a subcontractor agreement with TLS that included a nondisclosure provision. Rodriguez later began working for TLS and signed a nondisclosure agreement. After his departure from TLS Rodriguez provided tax services in competition with TLS through ASG and GOS. TLS alleged that Rodriguez and ASG misappropriated TLS's trade secrets and that Rodriguez, ASG, and GOS breached their nondisclosure agreements. The district court granted summary judgment to TLS on the breach of contract claims. After a non-jury trial on the trade secret claims, the district court found in favor of TLS. The First Circuit reversed, holding (1) TLS failed to satisfy its burden to prove the existence of trade secrets; and (2) the nondisclosure agreements were so broad as to be unenforceable. View "TLS Management & Marketing Services, LLC v. Rodriguez-Toledo" on Justia Law

In 2010, Appellant Chris Drakos loaned Respondent Garrett Sandow $200,000.00. A promissory note executed by Sandow on November 30, 2010, secured the loan. In 2018, after receiving no payments, Drakos filed a complaint seeking to collect on the Note. Sandow moved for summary judgment arguing that the statute of limitations barred the action. Drakos filed a cross-motion for summary judgment, arguing that the statute of limitations did not apply based on the Note’s clear language. The district court granted summary judgment to Sandow. Drakos moved the district court to reconsider, which the district court denied. Drakos timely appealed, arguing the district court erred in granting summary judgment for Sandow and in denying his motion for reconsideration. Finding no reversible error, the Idaho Supreme Court affirmed. View "Drakos v. Sandow" on Justia Law

The Supreme Court reversed the judgments of the Appellate Court determining that it was required to apply State v. Hossan-Maxwell, Inc., 436 A.2d 284 (Conn. 1980), to this case, holding that Hossan-Maxwell, Inc. is overruled.Plaintiffs and Defendants entered into agreements for the sale of property. Defendants included list-back provisions in their purchase and sale agreements for two parcels. Plaintiffs later filed suit alleging breach of contract and anticipatory breach. Defendants raised several defenses, arguing, as relevant to this appeal, that the list-back provisions in the parties' purchase and sale agreements were illegal tying arrangements. The trial court ruled for Defendants. The Appellate Court affirmed on the basis of the antitrust defense. The Supreme Court reversed, holding (1) the trial court should not have found the list-back agreements unenforceable without first engaging in a full market analysis, as a per se ban on list-back agreements, as applied in Hossan-Maxwell, Inc. is inconsistent with federal antitrust law as it has evolved over the decades; and (2) the trial court's judgments cannot be affirmed under the proper legal standard. View "Reserve Realty, LLC v. Windemere Reserve, LLC" on Justia Law

The First Circuit affirmed the district court's denial of Appellants' motion to compel arbitration in this putative class action, holding that the Federal Arbitration Act's (FAA) exemption for "contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce" encompasses the contracts of transportation workers who transport goods or people within the flow of interstate commerce.Plaintiff was a delivery driver for Amazon.com, Inc. and its subsidiary, Amazon Logistics, Inc. (collectively, Amazon) who collected packages for delivery in Massachusetts and did not cross state lines during the course of his deliveries. Plaintiff filed this putative class action asserting misclassification of Amazon's drivers contracted with through its smartphone application as independent contractors and violations of Massachusetts labor laws. Amazon moved to compel arbitration pursuant to the mandatory arbitration provision of Plaintiff's employment agreement with Amazon. The district court denied the motion in part, concluding that Plaintiff's agreement was exempt from the FAA and that the provision was unenforceable based on Massachusetts public policy. The First Circuit affirmed, holding (1) the FAA does not govern the enforceability of the dispute resolution section of the agreement; and (2) the district court rightly refused to compel arbitration pursuant to state law. View "Waithaka v. Amazon.com, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court denying a judgment creditor's motion for leave to execute on the judgment and its motion for reconsideration, holding that the district court did not abuse its discretion in viewing the judgment creditor's collection efforts as lacking in diligence and thus deeming unwarranted an extension of the period for execution of judgments.The district court entered a consent judgment in favor of Erikon LLC and against two defendants, jointly and severally, for $7.5 million. After Defendants stopped making payments, Erikon made no meaningful effort to collect the balance of the judgment for several years. Erikon eventually moved for leave to execute on the judgment. The district court denied the motion, reasoning that Erikon had waited to file its motion until more than six years after Defendants' final payment. The court then denied Erikon's motion for reconsideration. The First Circuit affirmed, holding that where, over the course of more than six years, Erikon took minimal steps to enforce the judgment, the district court did not abuse its discretion in deeming unwarranted an extension of the period for execution of judgments. View "Caribbean Management Group, Inc. v. Erikon, LLC" on Justia Law

The Supreme Court reversed the determination of the district court that a contract entered into by a dissolved partnership was void, holding that the contract was voidable.Two years after the Muir Second Family Limited Partnership was administratively dissolved, the former general partner of the partnership - Nicholas Muir - obtained a loan from the TNE Limited Partnership through a trust deed. Wittingham, LLC, a successor-in-interest to the Partnership, brought suit to declare the trust deed void and recover damages. The district court concluded that the trust deed was void because the Partnership was dissolved prior to the time Muir signed the trust deed. The Supreme Court reversed, holding that the trust deed was voidable because the relevant statutes failed to provide a clear and well-defined public policy indicating that the type of transaction here should be void and because the transaction deed did not harm the public as a whole. View "Wittingham v. TNE Limited Partnership" on Justia Law

Appellants-patients Nathaniel Valencia and Emily Williams were self-pay patients who received emergency medical services at Saint Alphonsus Medical Center—Nampa, Inc. (“Saint Alphonsus”) in 2015. During their respective visits, Patients agreed to pay for “all charges incurred” for services rendered to them. Patients were billed in accordance with Saint Alphonsus’ “chargemaster” rates. Patients sought declaratory relief requesting the district court to rule Saint Alphonsus was only entitled to bill and seek collection of the reasonable value of the treatment provided to self-pay patients. Saint Alphonsus moved the district court to dismiss the complaint pursuant to Idaho Rule of Civil Procedure 12(b)(6). The district court treated the motion to dismiss as a motion for summary judgment pursuant to I.R.C.P. 12(d). Ultimately, the district court granted summary judgment for Saint Alphonsus, and Patients timely appealed. Finding no reversible error, the Idaho Supreme Court affirmed. View "Williams v. St. Alphonsus Medical Center" on Justia Law

Jonathon Gregory appealed a district court’s award of summary judgment in favor of Richard and Eileen Stallings (collectively, “the Stallings”) in a breach-of-contract action stemming from the parties’ oral agreement to develop real property in Rexburg, Idaho. The property was sold in December 2012. Gregory, believing the Stallings wrongfully withheld a portion of the proceeds, filed a complaint in September 2017. The district court granted the Stallings’ subsequent motion for summary judgment, concluding that Gregory’s cause of action was barred by Idaho Code section 5-217’s four-year statute of limitations. After review, the Idaho Supreme Court determined the district court properly granted summary judgment to the Stallings because Gregory's cause of action was indeed barred by the statute of limitations in Idaho Code 5-217. Further, Gregory’s equitable-estoppel claim failed because he could not show that he pursued his claim in a reasonable amount of time. View "Gregory v. Stallings" on Justia Law