Contrary to the holding of the district court, Appellant filed a timely legal-malpractice claim under Minn. Stat. 541.05(1)(5).Respondent, Appellant’s attorney, prepared an antenuptial agreement for Appellant and his then-fiancee, Cynthia Gatliff, but the agreement did not include statutorily required witness signatures, making it unenforceable. One year after Appellant married Gatliff, Respondent drafted a will for Appellant that incorporated the antenuptial agreement by reference. When Gatliff later filed for divorce, she alleged that the antenuptial agreement was invalid due to its lack of witness signatures. Appellant subsequently sued Respondent for legal malpractice. While the invalid execution of the antenuptial agreement fell outside the six-year limitations period for malpractice claims, Appellant argued that subsequent representations by Respondent that the anteuptial agreement was valid were separate legal-malpractice claims that each triggered their own statute of limitations periods. The district court granted Respondent’s motion for judgment on the pleadings, and the court of appeals affirmed. The Supreme Court reversed, holding that Appellant sufficiently alleged that Respondent’s will drafting formed the basis for a separate malpractice claims within the limitations period. View "Frederick v. Wallerich" on Justia Law

MACOM’s predecessor developed semiconductors using gallium nitride (GaN), obtained patents related to that technology, and sold those patents to Infineon's predecessor, retaining rights under separate license agreement. That agreement defines a “Field of Use” characterized by GaN-on-silicon technology and licenses MACOM to practice the GaN patents within the “Field of Use only.” MACOM and Infineon share rights to practice the patents in the Field of Use. The agreement defines an “Exclusive Field” within the Field of Use in which MACOM has exclusive rights to practice the patents—even as against Infineon. Infineon notified MACOM that it believed MACOM had breached the agreement by making and selling products using GaN-on-silicon-carbide technology, which is distinct from GaN-on-Si technology and outside the Field of Use. MACOM responded that the GaN-on-SiC sales were minimal and that any breach had been cured. Infineon terminated the Agreement. MACOM sued, asserting contract claims and seeking a declaratory judgment of noninfringement and obtained a preliminary injunction. The Federal Circuit affirmed in part, agreeing that MACOM could likely establish that its activity outside the Field of Use did not breach the agreement and that MACOM would suffer irreparable harm in the absence of a preliminary injunction. The court vacated two sentences in the injunction for lacking specificity. View "MACOM Technology Solutions Holdings, Inc. v. Infineon Technologies Americas Corp." on Justia Law

Renasant Bank purchased a Financial Institution Bond (the Bond), which covers losses caused by employees only when certain criteria are met. A Mississippi statute, Miss. Code Ann. 81-5-15, requires bank employees to post fidelity bonds that protect against "acts of dishonesty." The Fifth Circuit held that, assuming arguendo that the Bond was governed by section 81-5-15, the Bond's terms were enforceable as written because they were consistent with the statute. The court agreed with the district court that the Bank failed to produce evidence necessary to support its breach-of-contract claim and thus was entitled to summary judgment. View "Renasant Bank v. St. Paul Mercury Insurance Co." on Justia Law

In this action challenging an insurance company’s doubling of Plaintiff’s insurance premium, the Seventh Circuit reversed the district court’s dismissal of Plaintiff’s complaint for failure to state a claim, holding that Plaintiff was entitled to relief on her contract claim and that the allegations Plaintiff raised were enough to permit her to go forward on her other theories.When Plaintiff was sixty-seven years old, she discovered that Metropolitan Life Insurance Company (MetLife) more than doubled her insurance premium. Plaintiff brought this lawsuit against MetLife on behalf of herself and a proposed class, alleging breach of contract, deceptive and unfair business practices, and common-law fraud. The district court granted MetLife’s motion to dismiss for failure to state a claim, concluding that the insurance policy unambiguously permitted MetLife to raise Plaintiff’s premium. The First Circuit disagreed, holding that the allegations raised in the complaint were enough to entitle Plaintiff to prevail on the liability phase of her contract claim and to go forward on her remaining claims. View "Newman v. Metropolitan Life Insurance Co." on Justia Law

Plaintiff Stacy Gaasch, as personal representative for the Estate of Troy Gaasch, filed suit against St. Paul File and Marine Insurance Company, alleging the insurance company failed to timely provide reasonable and necessary medical treatment as ordered by the Workers' Compensation Court. Troy required multiple surgeries over several years due to his work-related injury. Troy was hospitalized due to his work-related injury. He allegedly became malnourished with accompanying weight loss and different physicians recommended a nutritional consult. A nurse case manager recommended monthly a nutritional consult. Troy died during his hospitalization approximately six months after the initial recommendation for a nutritional consult. Prior to his work-related injury, Troy underwent a gastric bypass surgery and allegedly suffered from a malabsorption syndrome secondary to this surgery. A disagreement arose between insurer and Troy concerning whether the insurer was required to pay for a nutritional consult. Insurer claimed Troy's nutritional problems were created prior to his work-related injury and his nutritional state in the hospital was not due to the work-related injury. The company moved for summary judgment which was granted. Plaintiff appealed. The Oklahoma Supreme Court held: (1) Plaintiff's district court action alleging breach of contract also included a request for damages resulting from the death of the workers' compensation claimant; (2) the district court action was based upon alleged delay by a workers' compensation insurer in providing medical care as previously awarded by the Worker's Compensation Court; and (3) the district court action against the workers' compensation insurer was precluded by an exclusive remedy provided by the Workers' Compensation Act. “Plaintiff attempts to go around this procedure we classified as a ‘jurisdictional requirement’ . . .by characterizing the claim as a breach of contract and an action for damages resulting from an alleged wrongful death. The clear public policy expressed in the amended version of Art. 23 sec. 7 requires available workers' compensation remedies for any type of wrongful death claim to be pursued in the Workers' Compensation Court when required by the workers' compensation statutes.” View "Gaasch v. St. Paul Fire & Marine Ins. Co." on Justia Law

Oklahoma and the Citizen Potawatomi Nation (the “Nation”) entered into a Tribal-State gaming compact; Part 12 of which contained a dispute-resolution procedure that called for arbitration of disagreements “arising under” the Compact’s provisions. The terms of the Compact indicated either party could, “[n]otwithstanding any provision of law,” “bring an action against the other in a federal district court for the de novo review of any arbitration award.” In Hall Street Associates, LLC. v. Mattel, Inc., 552 U.S. 576, (2008), the Supreme Court held that the Federal Arbitration Act (“FAA”) precluded parties to an arbitration agreement from contracting for de novo review of the legal determinations in an arbitration award. At issue before the Tenth Circuit Court of Appeals was how to treat the Compact’s de novo review provision given the Supreme Court’s decision in Hall Street Associates. The Nation argued the appropriate course was to excise from the Compact the de novo review provision, leaving intact the parties’ binding obligation to engage in arbitration, subject only to limited judicial review under 9 U.S.C. sections 9 and 10. Oklahoma argued the de novo review provision was integral to the parties’ agreement to arbitrate disputes arising under the Compact and, therefore, the Tenth Circuit should sever the entire arbitration provision from the Compact. The Tenth Circuit found the language of the Compact demonstrated that the de novo review provision was a material aspect of the parties’ agreement to arbitrate disputes arising thereunder. Because Hall Street Associates clearly indicated the Compact’s de novo review provision was legally invalid, and because the obligation to arbitrate was contingent on the availability of de novo review, the Tenth Circuit concluded the obligation to arbitrate set out in Compact Part 12 was unenforceable. Thus, the matter was remanded to the district court to enter an order vacating the arbitration award. View "Citizen Potawatomi Nation v. State of Oklahoma" on Justia Law

The Fifth Circuit reversed the district court's grant of summary judgment for Cardtronics in a breach of contract action alleging that Cardtronics failed to correct certain account information, which resulted in approximately $250,000 of misdirected funds. The court held that the district court misread the contract and that Cardtronics was obligated to use correct account information after receiving updated Terminal Set-up Forms to ensure proper set up of Star Financial's ATMs. Accordingly, the court remanded for the district court to determine in the first instance whether Cardtronics breached its obligation under the contract and the appropriate damages, if any. View "Star Financial Services, Inc. v. Cardtronics USA, Inc." on Justia Law

United Propane Gas, Inc. ("United Propane"), sought a writ of mandamus compelling the Cullman Circuit Court to vacate its order denying United Propane's motion to dismiss an action filed by Cullman Security Services, Inc. ("CSS"), and to enter an order dismissing the action. The trial court denied the motion to dismiss on the ground that "the outbound forum-selection clause contained in the parties' contract is unfair or unreasonable because it deprives [CSS] of the ability to file a class action in contravention of a recognized Alabama public policy" and found that the parties' contract was a contract of adhesion. The Supreme Court concluded United Propane had shown a clear legal right to have the action dismissed on the basis that venue in the Cullman Circuit Court was, by application of the outbound forum-selection clause, improper. The trial court exceeded its discretion in denying the motion to dismiss CSS's action. The trial court was directed to dismiss the cause without prejudice. View "Ex parte United Propane Gas, Inc." on Justia Law

The district court erred in concluding that because of arbitration and venue provisions in an employment contract between the parties, it lacked jurisdiction.Nearly three years into the litigation in this case, the Douglas County District Court indefinitely stayed a claim for dissolution of one business entity, a party in the case, and dismissed sua sponte all other claims, noting that the employment contract contained arbitration and venue provisions that were outside the district court’s jurisdiction. The Supreme Court reversed the stay and dismissal order and remanded the case for further proceedings, holding that because no party sought to enforce the arbitration agreement, it was error for the district court to do so on its own accord. View "Boyd v. Cook" on Justia Law

Meyer, a disbarred lawyer, owns JHM, which installed and maintained laundry machines in apartment buildings; Dolphin, which sold commercial laundry equipment to JHM and others; and JH Meyer, which operated a laundry facility. In 2012-2013, Firestone financed JHM’s business with loans totaling about $250,000. Because JHM obtained its equipment from Dolphin, the loans actually financed Dolphin’s purchases from the manufacturer. Firestone retained a security interest in JHM’s assets. Dolphin, JH Meyer, and Meyer guaranteed JHM’s loan obligations. In 2013 Firestone sued JHM for default and sued Meyer, Dolphin, and JH Meyer under the guarantees. The defendants raised the affirmative defense and counterclaim of promissory estoppel, asserting that after Firestone issued JHM two loans, Firestone’s Vice President McAllister told Meyer that Firestone would set up a $500,000 line of credit for JHM and that, until the line of credit was established, Firestone would finance “any” equipment that JHM needed on “identical terms” to the first two loans. Firestone subsequently issued the third loan. After McAllister left Firestone, Firestone’s CEO approved the final loan. The defendants assert that Firestone’s refusal to issue further loans harmed them. The Seventh Circuit affirmed summary judgment in favor of Firestone. Meyer’s allegations were implausible because no financial firm would commit orally to loaning substantial sums to a startup. Meyer conceded that he “made no payments” to Firestone. A reasonable jury could not conclude that Meyer has satisfied any of the elements of promissory estoppel. View "Firestone Financial Corp. v. Meyer" on Justia Law