The plaintiffs, employees of the State of California providing dental care to inmates, filed a lawsuit seeking compensation for time spent on pre- and post-shift safety and security activities. These activities included going through security and handling alarm devices. The defendants, including the State of California and related departments, filed a demurrer, arguing that these activities were not compensable under the Portal-to-Portal Act of the Fair Labor Standards Act (FLSA). The trial court sustained the demurrer without leave to amend, leading to the plaintiffs' appeal.The trial court ruled that the activities in question were not integral and indispensable to the plaintiffs' principal work of providing dental care, thus not compensable under the FLSA. The plaintiffs argued that the trial court improperly decided a factual question and that their claims were viable. The defendants maintained that the trial court's decision was correct and also argued that the plaintiffs' claims were precluded by the Memorandum of Understanding (MOU) governing their employment, that the relevant statutes did not apply to government employers, that the plaintiffs failed to exhaust contractual remedies, and that the claims were time-barred.The California Court of Appeal, First Appellate District, Division Two, concluded that the trial court erred in not accepting the plaintiffs' allegations as true for the purposes of the demurrer. The appellate court found that the plaintiffs had stated a claim for breach of contract and that the defendants' affirmative defense of failure to exhaust contractual remedies could not be resolved at the demurrer stage. The court also determined that the plaintiffs' contract claim was not time-barred. Consequently, the appellate court affirmed the trial court's decision in part and reversed it in part, allowing the breach of contract claim to proceed. View "Bath v. State" on Justia Law

Richard Andrew Justice filed a claim against the Georgia Department of Public Safety (DPS) for breach of an employment contract, alleging that DPS failed to pay him for overtime hours as required under the Fair Labor Standards Act (FLSA). Justice argued that the FLSA provisions were incorporated into his employment contract. The central issue was whether Justice had demonstrated the existence of a written contract sufficient to overcome DPS’s motion to dismiss on sovereign immunity grounds.The trial court allowed limited discovery and reviewed documents submitted by Justice, including a written offer of employment and subsequent communications. The trial court ultimately granted DPS’s motion to dismiss, finding that the documents did not constitute a valid written contract and that there was no meeting of the minds regarding FLSA overtime compensation provisions. The Court of Appeals reversed this decision, concluding that the documents did form a written contract that included FLSA provisions, thereby waiving sovereign immunity.The Supreme Court of Georgia reviewed the case and determined that Justice had shown the existence of a written contract with DPS, which established a waiver of sovereign immunity under the ex contractu clause of the Georgia Constitution. The Court held that the question of whether the FLSA obligations were part of the written contract was a merits question, not a sovereign immunity question, and thus was not properly before the trial court on a motion to dismiss for lack of subject-matter jurisdiction. The Supreme Court affirmed the Court of Appeals' decision in part, vacated it in part, and remanded the case for further proceedings consistent with its opinion. View "GEORGIA DEPARTMENT OF PUBLIC SAFETY v. JUSTICE" on Justia Law

The plaintiffs, who operate restaurants under franchise agreements, filed a Chapter 11 bankruptcy petition based on advice from their legal counsel. This led to the franchisor terminating the franchise agreements. The plaintiffs then sued their lawyers and law firms for legal malpractice and breach of written contracts for legal services, alleging that the lawyers' advice constituted malpractice. The defendants moved to dismiss both claims, arguing they were barred by a four-year statute of limitation under OCGA § 9-3-25.The trial court dismissed the legal-malpractice claims but denied the motion to dismiss the breach-of-contract claims. Later, it granted summary judgment for a subset of defendants, ruling that the breach-of-contract claims were also barred by the four-year statute of limitation. The Court of Appeals affirmed the dismissal of the legal-malpractice claims and concluded that the breach-of-contract claims were duplicative and should be dismissed as well.The Supreme Court of Georgia reviewed the case to determine which statute of limitation applies to breach-of-contract-for-legal-services claims and whether the Court of Appeals erred in dismissing these claims as duplicative. The Supreme Court concluded that such claims could be governed by either a six-year statute of limitation under OCGA § 9-3-24 or a four-year statute under OCGA § 9-3-25, depending on whether the breach arose directly from a written contract. The Court also held that the Court of Appeals erred in dismissing the breach-of-contract claims as duplicative without applying the proper motion-to-dismiss standard.The Supreme Court vacated the Court of Appeals' judgment and remanded the case for further proceedings consistent with its opinion, emphasizing that plaintiffs can pursue alternative theories of relief based on the same conduct. View "TITSHAW v. GEER" on Justia Law

The case involves a dispute between two companies, Plaintiff Fuel Automation Station, LLC, and Defendant Energera Inc., both of which operate in the fuel industry and hold patents related to automated fuel delivery equipment. The conflict arose after Defendant, despite agreeing not to sue Plaintiff for patent infringement, initiated lawsuits against Plaintiff’s affiliated entity and subcontractor for using Plaintiff’s equipment, alleging infringement of a Canadian patent (the 567 Patent).The United States District Court for the District of Colorado initially reviewed the case. The court found that the covenant not to sue included the relevant parties but was ambiguous regarding whether it covered the 567 Patent. The court applied ordinary rules of contract construction and the patent exhaustion doctrine, which led to the conclusion that the covenant did protect downstream users of Plaintiff’s equipment. The district court granted partial summary judgment in favor of Plaintiff on this basis. However, it found genuine issues of material fact regarding whether the 567 Patent was included in the Patent Rights defined in the agreement, leading to a jury trial. The jury determined that the Patent Rights did cover the 567 Patent and that Defendant had breached the covenant not to sue.The United States Court of Appeals for the Tenth Circuit reviewed the case. The appellate court affirmed the district court’s rulings. It held that the covenant not to sue did indeed extend to downstream users under the patent exhaustion doctrine, meaning Defendant could not sue Plaintiff’s customers for using the equipment. Additionally, the appellate court agreed with the district court and the jury that the Patent Rights included the 567 Patent, thus supporting the finding that Defendant breached the covenant by suing Plaintiff’s affiliated entity and subcontractor. The appellate court affirmed the district court’s judgment in favor of Plaintiff. View "Fuel Automation Station v. Energera" on Justia Law

In November 2014, the plaintiff purchased a recreational vehicle (RV) from a dealership, with the defendant bank financing the purchase. The sales contract inaccurately reflected the downpayment as $19,100 in cash instead of $1,000 in cash and $18,100 in trade-in value. The plaintiff later discovered issues with the RV and filed a lawsuit in February 2017, alleging violations of the Automobile Sales Finance Act (ASFA) due to the incorrect downpayment disclosure.The Superior Court of Fresno County reviewed the case and concluded that the four-year statute of limitations for written contracts applied, rather than the one-year statute for statutory penalties. The court granted summary adjudication in favor of the plaintiff against the dealership for violating the ASFA, and the dealership's liability was extended to the bank under the Federal Trade Commission’s holder rule. The court entered judgment requiring the bank to accept the return of the RV and pay the plaintiff $42,263.64.The California Court of Appeal, Fifth Appellate District, reviewed the case and determined that the rescission and restitution remedy under the ASFA is a penalty. The court concluded that the one-year statute of limitations for actions upon a statute for a penalty or forfeiture applied. The court noted that the ASFA imposes strict liability without regard to actual damages or fault, and the legislative history indicated the remedy was intended as a penalty. Consequently, the appellate court reversed the trial court's decision and remanded the case for further proceedings consistent with its opinion. View "Pompey v. Bank of Stockton" on Justia Law

Ultra Deep Picasso Pte. Limited (Ultra Deep) is a contractor specializing in undersea vessel operations for marine construction. Dynamic Industries Saudi Arabia Ltd. (Dynamic) subcontracted Ultra Deep for a project related to a contract with Saudi Aramco. Ultra Deep completed work worth over ten million dollars but alleged that Dynamic failed to pay, breaching their agreement. Ultra Deep filed a complaint in the Southern District of Texas, seeking breach of contract damages and a maritime attachment and garnishment of Dynamic’s funds allegedly held by Riyad Bank.The district court granted Ultra Deep an ex parte order for attachment of Dynamic’s assets at Riyad Bank. Dynamic responded with motions to dismiss for lack of personal jurisdiction, improper venue, and to compel arbitration, which were denied. Dynamic and Riyad Bank then moved to vacate the attachment order, arguing that Ultra Deep failed to show Dynamic had property in the Southern District of Texas. The magistrate judge held a hearing and found that Ultra Deep did not present evidence that Dynamic’s property was within the district. The district court adopted the magistrate judge’s recommendation, vacated the attachment order, and dismissed the case with prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that for a valid Rule B attachment, the property must be found within the district. It concluded that a bank account is located where its funds can be withdrawn. Since Ultra Deep failed to show that Dynamic’s property was within the Southern District of Texas, the court affirmed the district court’s decision to vacate the attachment order and dismiss the case. View "Ultra Deep Picasso v. Dynamic Industries Saudi Arabia Ltd." on Justia Law

The case involves a dispute over a real estate transaction between Francesco Scotti and Matthew Mimiaga concerning a property at 300 Benefit Street in Providence, Rhode Island. In 2015, Scotti sold the property to Mimiaga, who financed the purchase through a promissory note. As part of the transaction, Scotti was granted an option to repurchase the property within five years for $900,000. Scotti claimed he exercised this option by mailing a handwritten letter to Mimiaga on June 1, 2020, but Mimiaga denied receiving it. Scotti also alleged that Mimiaga requested extensions to stay on the property due to COVID-19 and other issues, which he granted.The Superior Court granted summary judgment in favor of Mimiaga, ruling that the option agreement lacked separate consideration, Scotti did not properly exercise the option, and there was no express or implied waiver of the option's terms. The court found no evidence that Mimiaga received the June 1, 2020 letter and concluded that Scotti did not act timely to repurchase the property.The Rhode Island Supreme Court reviewed the case and vacated the Superior Court's judgment. The Supreme Court held that the option agreement was supported by consideration as stated in the written document. It also found that a genuine issue of material fact existed regarding whether Mimiaga received the June 1, 2020 letter, invoking the presumption that mailed notices are received. Additionally, the court determined that whether time was of the essence and whether there was an implied waiver of the option's terms were genuine issues of material fact that precluded summary judgment. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Scotti v. Mimiaga" on Justia Law

Sage Acquisitions LLC ("Sage") entered into contracts with the United States Department of Housing and Urban Development ("HUD") to provide management and marketing services for properties in HUD's Real Estate Owned ("REO") disposition program. Sage was awarded three contracts for different geographic areas. Sage filed claims with the HUD contracting officer for settlement costs due to the termination for convenience of the contracts, equitable adjustments for reduced property assignments, and damages for scope reduction. Sage also claimed damages for HUD's alleged breach of a contractual option provision and a related bridge contract.The Civilian Board of Contract Appeals ("Board") denied Sage's claims. The Board held that the contracts were Indefinite Delivery/Indefinite Quantity ("IDIQ") contracts, not requirements contracts, and that HUD had met its obligations by ordering the guaranteed minimum quantities. The Board also found that HUD did not breach the contracts by issuing six-month task orders instead of one-year orders and that HUD did not breach the bridge contract by using REO alternatives.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the Board's decision. The court held that the contracts were indeed IDIQ contracts, as they explicitly stated and included guaranteed minimums. The court found that the language in the contracts did not confer exclusivity to Sage, and HUD's reservation of the right to work with other contractors was incompatible with a requirements contract. The court also held that HUD's issuance of six-month task orders was permissible under the contract terms. Finally, the court concluded that HUD did not breach the bridge contract, as Sage was aware of HUD's use of REO alternatives, and HUD's actions were based on legitimate business purposes. View "SAGE ACQUISITIONS LLC v. HUD " on Justia Law

Hexagon US Federal, Inc. ("HexFed") leased a portion of a building from Intergraph Unimproved Properties, LLC in 2015. The lease included two bays with different terms and renewal options. In 2016, the lease was amended to provide a five-year term for both bays. CBS Holdings, LLC later acquired the building and the lease. A dispute arose over whether HexFed had validly renewed the lease, leading HexFed to file a lawsuit against CBS Holdings for breach of the lease agreement.The Madison Circuit Court held a bench trial and ruled in favor of HexFed, finding that CBS Holdings had waived its right to argue that the lease for one of the bays had expired after 12 months. The court also reformed the lease to correct a mutual mistake, establishing that the maximum monthly rent for the bay did not expire after one year. The court declared that HexFed had properly exercised its renewal option and awarded HexFed costs and attorneys' fees.The Supreme Court of Alabama reviewed the case and affirmed the lower court's judgment. The court held that CBS Holdings had waived its argument about the lease term by accepting rent without objection and by executing a lease amendment without changing the lease term. The court also upheld the reformation of the lease, finding clear evidence of a mutual mistake. Additionally, the court agreed that HexFed had validly renewed the lease by providing timely written notice, despite an error in the rent calculation. Finally, the court affirmed the award of costs and attorneys' fees to HexFed, as it was forced to file the action to enforce the lease. View "CBS Holdings, LLC v. Hexagon US Federal, Inc." on Justia Law

In 2020, First United Pentecostal Church in DeQuincy, Louisiana, sustained significant damage from Hurricanes Laura and Delta. The church was insured by Church Mutual Insurance Company (CM), which covered several buildings on the property. After the hurricanes, First United submitted a claim to CM, but CM delayed the inspection and payment process. CM eventually made two payments totaling $191,832.28, which the church used for repairs. Dissatisfied with the amount and timing of the payments, First United filed a lawsuit against CM, alleging breach of contract and violations of Louisiana insurance statutes.The United States District Court for the Western District of Louisiana held a bench trial and found in favor of First United. The court concluded that CM had acted in bad faith by failing to make timely payments and awarded First United $1,101,122.87 in unpaid losses, along with statutory penalties, attorney fees, and costs, bringing the total award to $2,073,838.96. The court later amended the judgment to $2,052,335.09 after correcting some errors. CM's motions for a new trial and for judgment as a matter of law were denied, leading to this appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decisions on several points, including the denial of CM's motion to exclude First United's expert, Kermith Sonnier, and the use of Sonnier's estimate to calculate damages. However, the appellate court reversed the district court's imposition of statutory penalties, attorney fees, and costs, finding that CM's actions were not arbitrary, capricious, or without probable cause. The case was remanded for further proceedings consistent with the appellate court's opinion. View "First United v. Church Mutual Insurance" on Justia Law