The case revolves around a dispute over oil and gas interests between Spottie, Inc., a Nevada corporation, and several other Nevada corporations and a limited liability company. Spottie alleged that the defendants had wrongfully claimed title to these interests, which were once owned by Edward Davis, who had formed Spottie as a holding company. The defendants countered that they had entered into an agreement with Davis to acquire these interests, and that Davis and Spottie had transferred the disputed interests to one of the defendants via an assignment in 2016.The district court dismissed several of Spottie's claims, leaving only a quiet title claim and a claim for unjust enrichment. After a three-day bench trial, the court ruled in favor of the defendants, finding that the assignment from Davis and Spottie to one of the defendants was valid. The court also found that Spottie had erroneously received revenue from the disputed interests and awarded damages to the defendants.Spottie appealed the decision, arguing that the district court had erred in its ownership determination, its rejection of Spottie's laches defense, its binding of a non-party to the judgment, and its award of attorney fees and costs. The Supreme Court of North Dakota affirmed in part, concluding that the district court did not err in its ownership determination and its award of attorney fees. However, it reversed in part, finding that the court had erred in awarding costs for non-legal expenses. The case was remanded for the court to recalculate its cost award and to consider the defendants' request for additional attorney fees and legal costs. View "SPOTTIE v. BAIUL-FARINA" on Justia Law

The case revolves around a dispute over the ownership of a purebred show dog named Oscar. The parties involved are Oscar's breeder, Elizabeth "Betsy" Shauck, and Dave Jennings and Emily McLeod, who have raised Oscar since he was a puppy. Dave and Emily filed a petition to quiet title to Oscar against Betsy, who counterclaimed for breach of contract, replevin, conversion, for a restraining order and preliminary injunction, and to quiet title. Betsy's preliminary injunction counterclaim asked the district court to prevent Dave and Emily from harboring Oscar and to order his immediate return to her.The district court held a three-day hearing, which was supposed to be on Betsy's request for a preliminary injunction. However, the court expanded the scope of the hearing and made findings of fact and conclusions of law on the merits of all issues pending in the underlying lawsuit, including Oscar's ownership, contract disputes, and damages. Dave and Emily appealed this decision, arguing that the district court denied their due process rights by deciding the case on the merits when it had only set the hearing on Betsy's preliminary injunction.The Kansas Court of Appeals panel held that the district court violated Dave and Emily's due process rights by expanding the scope of the hearing without notice. However, instead of remanding the case, the panel analyzed the parties' ownership interests in Oscar and held that Dave and Betsy co-owned Oscar. Betsy then petitioned the Supreme Court of the State of Kansas for review.The Supreme Court of the State of Kansas affirmed in part and reversed in part the decision of the panel. The court agreed with the panel that the district court erred by expanding the scope of the hearing on Betsy's request for a preliminary injunction. The court found that the district court's decision to consolidate the hearing on Betsy's request for a preliminary injunction with a trial on the case's merits without informing the parties was a denial of due process and an error of law. The court also agreed with the panel's conclusion that the district court's failure prejudiced Dave and Emily. However, the court held that the panel erred by addressing the case's merits after correctly concluding that the district court erred. The court reversed the judgment of the district court and remanded the case for further proceedings. View "Jennings v. Shauck" on Justia Law

The case involves a dispute between the Terrace Hill Society Foundation (THSF) and the Terrace Hill Commission (the Commission) over the ownership and control of a collection of property and historical artifacts displayed at the Governor's official residence, Terrace Hill. THSF filed a petition seeking a declaration that it was the sole owner of the collection and an injunction granting it the right to access, itemize, insure, maintain, and preserve the collection. The Commission and its chairperson, Kristin Hurd, moved to dismiss the suit, arguing that it was barred by the doctrine of sovereign immunity and that Hurd could not provide the requested relief.The district court denied the motion to dismiss with respect to the Commission, finding that the factual allegations in the petition, when viewed in the light most favorable to THSF, were sufficient to overcome the State's immunity from suit. The court reasoned that the Commission had willingly accepted possession of THSF's property and retained it after the expiration of a 1996 agreement between the parties. However, the court granted the motion to dismiss with respect to Hurd and dismissed the claims against her without prejudice.On appeal, the Supreme Court of Iowa affirmed the district court's decision. The court held that the State can impliedly or constructively waive its immunity from suit when it voluntarily creates certain legal relationships that subject it to liability. The court found that THSF's amended petition alleged sufficient facts to plead a voluntary bailment, a legal relationship sounding in contract, which impliedly waived the State's sovereign immunity. The court also affirmed the dismissal of the claims against Hurd without prejudice, rejecting her argument that the claims should have been dismissed with prejudice. The case was remanded for further proceedings. View "Terrace Hill Society Foundation v. Terrace Hill Commission" on Justia Law

In April 2013, Brandi Stiles and Abel Gorgita purchased a 2011 Kia Optima, which was manufactured and distributed by Kia Motors America, Inc. At the time of purchase, some of Kia's original warranties were still in effect, including the basic and drivetrain warranties. The car developed serious defects covered by the warranties, including issues with the transmission, electrical system, brakes, engine, suspension, and steering. Despite multiple attempts, Kia was unable to repair the defects. Stiles and Gorgita alleged that Kia failed to replace the car or make restitution as required under the Song-Beverly Consumer Warranty Act.Kia demurred to the first amended complaint, arguing that the remedies sought under the Song-Beverly Act apply only to new motor vehicles, and the car purchased by Stiles and Gorgita was not a "new motor vehicle" as defined in the Act. The trial court sustained Kia's demurrer, relying on a previous case, Rodriguez v. FCA US, LLC, which held that a used motor vehicle with an unexpired warranty is not a "new motor vehicle" under the Song-Beverly Act.The Court of Appeal of the State of California Second Appellate District Division Six reversed the trial court's decision. The court held that a previously owned motor vehicle purchased with the manufacturer’s new car warranty still in effect is a “new motor vehicle” as defined by the Song-Beverly Act. Therefore, the replace or refund remedy of the Act applies. The court rejected Kia's argument that the Act's definition of a "new motor vehicle" should be limited to vehicles that have never been previously sold to a consumer and come with full express warranties. The court also rejected Kia's argument that Stiles and Gorgita's interpretation of the Act conflicts with its implied warranty provisions. View "Stiles v. Kia Motors America, Inc." on Justia Law

The case involves a group of bettors who sued Churchill Downs, Inc., and trainers Robert Baffert and Bob Baffert Racing, Inc., after the horse they bet on, Medina Spirit, was disqualified from the 2021 Kentucky Derby due to a failed post-race drug test. The bettors claimed that they would have won their bets under the new order of finish after Medina Spirit's disqualification. However, under Kentucky law, only the first order of finish marked "official" counts for wagering purposes. The plaintiffs brought claims for negligence, breach of contract, violation of the Kentucky Consumer Protection Act, and unjust enrichment.The case was initially heard in the United States District Court for the Western District of Kentucky, which granted the defendants' motions to dismiss and denied the plaintiffs leave to amend the complaint. The court found that the plaintiffs' claims were based on the theory that they had "unpaid winning wagers," but under Kentucky law, the first official order of finish is final. Therefore, the plaintiffs' wagers were lost, and the complaint failed to state a claim upon which relief could be granted.The case was then appealed to the United States Court of Appeals for the Sixth Circuit. The appellate court affirmed the lower court's decision, agreeing that the plaintiffs' claims were based on the theory that they had "unpaid winning wagers." However, under Kentucky law, the first official order of finish is final for wagering purposes. Therefore, the plaintiffs' wagers were lost, and the complaint failed to state a claim upon which relief could be granted. The court also found that the proposed amendment to the complaint did not cure this flaw, so the lower court properly denied leave to amend. View "Mattera v. Baffert" on Justia Law

In 2011, James Buchl and Doren Chatinover, electrical engineers with experience in oil fields, entered into an oral contract with Gascoyne Materials Handling & Recycling to work as project managers for a division of Gascoyne. After five years, Gascoyne stopped making monthly payments under the contract, leading the plaintiffs to end the relationship and file a lawsuit. The plaintiffs' initial complaint alleged eleven causes of action, including fraud and deceit, which were dismissed by the district court. The case proceeded to a bench trial on the remaining claims for breach of contract and conversion, and on Gascoyne’s counterclaims.The district court found that Gascoyne had underpaid the plaintiffs by $822,199 and entered judgment in their favor for that amount, plus prejudgment and post-judgment interest. The court dismissed Gascoyne’s counterclaims. Gascoyne filed a post-trial motion to alter or amend, raising the issues now presented on appeal. The district court modified the award of post-judgment interest but otherwise denied the motion.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed all but $14,650 of the award of contract damages and the award of costs, reversed the grant of prejudgment interest, and remanded for entry of an amended judgment. The court found that the district court had not made a clear error in calculating the profits due to the plaintiffs, except for failing to include $29,300 in expenses for a particular project, which would reduce the plaintiffs' share of the profits by $14,650. The court also held that the plaintiffs' contract damages were not certain and were not capable of being made certain by calculation, so the district court erred in awarding prejudgment interest. View "Buchl v. Gascoyne Materials" on Justia Law

HotChalk, LLC filed a lawsuit against the Lutheran Church—Missouri Synod and 22 other defendants, alleging breach of contract and fraud in relation to the closure of Concordia University - Portland. HotChalk claimed that the Synod orchestrated the university’s closure to financially benefit itself and its affiliates while leaving the university’s creditors out in the cold. During discovery, the Synod sought a protective order to prevent the disclosure of certain documents related to internal religious matters. The trial court granted the protective order, effectively denying a motion to compel discovery of those documents. HotChalk then filed a petition for mandamus.The trial court's decision to grant the protective order was based on an in-camera review of the documents in question. The court equated the Synod's motion to a motion to restrict discovery to protect a party from embarrassment. After completing its final in-camera review, the trial court granted the Synod's motion for a protective order. HotChalk then filed a timely petition for mandamus in the Supreme Court of the State of Oregon.The Supreme Court of the State of Oregon issued an alternative writ of mandamus, directing the trial court to either vacate its order or show cause why it should not do so. The trial court declined to vacate its order, leading to arguments in the Supreme Court. The Synod argued that the writ should be dismissed because HotChalk has a plain, speedy, and adequate remedy in the ordinary course of the law. The Supreme Court agreed with the Synod, stating that HotChalk had not established that the normal appellate process would not constitute a plain, speedy, and adequate remedy in this case. Therefore, the Supreme Court dismissed the alternative writ as improvidently allowed. View "Hotchalk, Inc. v. Lutheran Church--Missouri Synod" on Justia Law

This case involves a dispute over a contract zone agreement that would have allowed development on a property in Saco, Maine. The property owners, Amarjit Singh Dhillon and Ajinder Kaur, appealed from a lower court's grant of partial summary judgment to Michael Dahlem, who owns neighboring property and challenged the contract zone agreement. Dahlem cross-appealed from the court's dismissal of his Rule 80B appeal and denial of his motion to reconsider that dismissal, and from the court's denial of summary judgment on two counts in his complaint.The lower court had granted summary judgment to Dahlem on several counts, declaring that the 2017 agreement became null and void in 2019 and thereafter could not be amended, was invalid and unlawful for noncompliance with the City’s contract zoning ordinance, and was inconsistent with Maine’s Mandatory Shoreland Zoning statute and therefore preempted and invalid. The court denied summary judgment to all parties on the count of whether the 2021 agreement was compatible with the City’s comprehensive plan.The Maine Supreme Judicial Court affirmed the lower court's decision in all respects and dismissed Dahlem’s cross-appeal as moot. The court held that Dahlem properly challenged the 2021 agreement by asserting claims for declaratory relief, that the 2017 agreement became null and void on November 20, 2019, and could not thereafter be amended, that the 2021 agreement was invalid and unlawful under the City’s contract zoning ordinance, and that the 2021 agreement was preempted by the Mandatory Shoreland Zoning provisions. View "Dahlem v. City of Saco" on Justia Law

The case originated as a class action dispute about the underpayment of oil and gas royalties due on wells in Oklahoma. The plaintiff, Chieftain Royalty Company, sued SM Energy Company, the operator of the wells, under various tort theories, including fraud, breach of contract, and breach of fiduciary duty. In 2015, the claims were settled for approximately $52 million. Following the settlement, Chieftain's counsel moved for attorneys’ fees, and Chieftain sought an incentive award for its CEO, Robert Abernathy. Two class members objected to the awards and appealed. The court affirmed the settlement but reversed the attorneys’ fees and incentive awards, remanding to the district court for further proceedings.On remand, the district court re-awarded the fees and incentive award. The class did not receive notice of the 2018 attorneys’ fees motion as required under Federal Rule of Civil Procedure 23(h)(1), so the court vacated the district court order awarding attorneys’ fees and remanded with instructions to direct class-wide notice of the 2018 attorneys’ fees motion and to re-open the period for objections. The court did not reach the merits of the appellate challenge to the re-awarded attorneys’ fees. The court affirmed the district court’s incentive award to Mr. Abernathy. View "Chieftain Royalty Company v. SM Energy Company" on Justia Law

This case involves a dispute between two tribally owned businesses, AQuate II, LLC and Kituwah Services, LLC, both of which compete for federal contracts under the Small Business Administration’s 8(a) Business Development Program. AQuate alleges that Kituwah and its employee, Jessica Myers, stole trade secrets related to a government contract that AQuate had won in the past. AQuate claims that Myers, a former employee, breached her employment agreements and violated both the Defend Trade Secrets Act of 2016 and the Alabama Trade Secrets Act. Kituwah, however, argues that it is shielded by tribal sovereign immunity, while Myers contends that her employment contract mandates that any claims against her can only be brought in a designated tribal court.The United States District Court for the Northern District of Alabama dismissed the case, finding that Kituwah had not waived sovereign immunity for the trade secrets claims and that the claims against Myers should be resolved in the Alabama-Quassarte Tribal Town court, as stipulated in her employment contract. AQuate appealed the decision, arguing that the tribal court did not exist.The United States Court of Appeals for the Eleventh Circuit reversed the district court’s decision. The appellate court found that Kituwah had waived sovereign immunity for claims related to the federal contracting program and could be sued. Regarding Myers, the court determined that the district court failed to consider whether the clause naming the allegedly nonexistent tribal court as the appropriate forum was valid and enforceable. The case was remanded for further consideration. View "Aquate II, LLC v. Myers" on Justia Law