Justia Contracts Opinion Summaries

Greving has lived and farmed in southeastern Wisconsin since 1971. In 2003 he began contracting to sell his grain to Northern Grain, an Illinois-based grain buyer. Northern Grain claimed that Greving repudiated several contracts formed years after the parties first began contracting and sought almost $1 million in damages. When Greving refused to arbitrate, Northern Grain sought an order compelling arbitration. The Illinois district court dismissed for lack of personal jurisdiction. The Seventh Circuit affirmed. Greving lacks minimum contacts with Illinois that would permit the district court, consistent with the due process clause, to exercise specific personal jurisdiction over him. Greving only set foot in Illinois once, to attend a seed-corn meeting in 2003, months before the parties entered into the first of their contracts, where he met Wilson, who became his contact with Northern Grain. Even assuming that his attendance at the meeting would enter the “personal-jurisdiction calculus for the later-formed contracts at issue,” there is no indication that Greving attended the meeting in an effort to find grain buyers. Virtually everything else about Greving’s contractual relationship with Northern Grain was based in Wisconsin. View "N. Grain Mktg., LLC v. Greving" on Justia Law

Christine and David Colburn leased property from Robert Hartshorn and agreed to care for Hartshorn's cattle. Neither the terms of the cattle care agreement or the lease agreement were reduced to writing. After a dispute, the Colburns served on Hartshorn an agister's lien for caring for Hartshorn's cattle. The Colburns also brought an action to recover amounts due for their care of Hartshorn's cattle and to foreclose the lien. Ultimately, the Colburns received a court order to sell the calves. The circuit court ruled that the Colburns were entitled to one half the net calf sale proceeds from the sale but found the agister's lien invalid under the terms of the parties' implied contract because the cattle were cared for on Hartshorn's land and not the Colburns' land. The Supreme Court reversed, holding that nothing in the state's laws governing agister's liens defeats their validity when cattle are entrusted to a caretaker on the cattle owner's land. Remanded. View "Colburn v. Hartshorn" on Justia Law

Plaintiff, which owned and operated a ranch, hired Defendant as a custom seeder to seed a barley crop grown under a contract with Circle S Seeds of Montana, Inc. The crop could not be harvested on schedule, and a heavy October snow later destroyed the crop. Plaintiff sued Defendant for breach of contract, alleging that crop did not ripen in time because of improper seed placement. The district court denied and dismissed with prejudice Plaintiff's breach of contract claim, concluding that Defendant did not materially breach its contract with Plaintiff. The Supreme Court affirmed, holding that the district court did not err in finding Defendant did not breach the contract by failing to object to rocky field conditions or by failing to achieve uniform depth of seed placement. View "CNJ Distrib. Corp. v. D & F Farms, Inc." on Justia Law

In 1990 Plummer, a recognized expert in horse-breeding and the tax consequences of related investments, created the Mare Lease Program to enable investors to participate in his horse-breeding business and take advantage of tax code provision classification of horse-breeding investments as farming expenses, with a five-year net operating loss carryback period instead of the typical two years, 26 U.S.C. 172(b)(1)(G). Plummer’s investors would lease a mare, which would be paired with a stallion, and investors could sell resulting foals, deducting the amount of the initial investment while realizing the gain from owning a thoroughbred foal. If they kept foals for at least two years, the sale qualified for the long-term capital gains tax rate, 26 U.S.C. 1231(b)(3)(A). Between 2001 and 2005, the Program generated more than $600 million. Law and accounting firms hired by defendants purportedly vetted the Program. Plummer and other defendants began funneling Program funds into an oil-and-gas lease scheme. It was later discovered that the Program’s assets were substantially overvalued or nonexistent. Investors sued under the Racketeer Influenced and Corrupt Organizations Act, 18 U.S.C. 1962(c), also alleging fraud and breach of contract. The district court granted summary judgment and awarded $49.4 million with prejudgment interest of $15.6 million. The Sixth Circuit affirmed, stating that there was no genuine dispute over any material facts. View "West Hills Farms, LLC v. ClassicStar Farms, Inc." on Justia Law

General Mills sued Five Star for breach of contract and breach of warranties after the meatballs General Mills purchased from Five Star contained beef that was recalled. The district court granted summary judgment to General Mills on the breach-of-contract claim and to Five Star on the breach-of-warranty claims. The parties cross-appealed. The court concluded that the press release that General Mills relied upon to recall the meatballs constituted hearsay. However, the press release set out findings from an investigation pursuant to authority granted by law and was therefore admissible. The court also concluded that sufficient admissible evidence supported the conclusion that the meat was procured in violation of regulations and that it was adulterated. Therefore, the district court properly granted summary judgment to General Mills on the breach-of-contract claim. The court further concluded that the district court properly analyzed the breach-of-contract and breach-of-warranties claims separately. The court dismissed General Mills' cross-appeal as moot and affirmed the award of attorneys fees to General Mills. View "General Mills Operations, LLC v. Five Star Custom Foods, Ltd." on Justia Law

The Scotts Company, an Ohio LLC, brought a diversity action against Seeds, Inc., a Washington corporation, in federal district court. Thereafter, Millhorn Farmers, Maple Leaf Farms, Mica Creek, and Tim Freeburg (Growers) sued Seeds and Scotts in Washington state court. Maple Leaf Farms and Mica Creek were Washington corporations, Millhorn Farms was an Idaho corporation, and Tim Freeburg was a citizen of Idaho. Scotts subsequently filed an amended complaint in federal court adding the Growers as defendants and seeking declaratory relief. The district court subsequently realigned the Growers and plaintiffs and Seeds and Scotts as defendants and held, alternatively, that it would stay the federal proceedings in favor of the related state court proceedings under either the Brillhart doctrine or the Colorado River doctrine. Because the parties' realignment resulted in the absence of complete diversity of citizenship between defendant Seeds and newly-aligned plaintiffs-Growers, the district court dismissed the action for lack of subject matter jurisdiction. The Ninth Circuit Court of Appeals reversed, holding that the district court should not have declined to entertain the claim for declaratory relief under the Brillhart doctrine, and instead, the claims should have been evaluated under the Colorado River doctrine. Remanded. View "Scotts Co., LLC v. Seeds, Inc." on Justia Law

This declaratory judgment action concerned a controversy over the limits of an insurance policy issued by Insurer to Insured. A livestock company (Company) brought suit in Minnesota state court against Insured after Company's cattle in Insured's care died in unusually high numbers. Insured submitted the complaint in the underlying action to Insurer. Insurer refused to defend or indemnify Insured in the case brought by Company, basing its denial of coverage on an exclusion in the liability insurance policy for damage to property in the "care, custody, or control" of the insured. The Minnesota district court entered judgment against Insured. Insurer then commenced this action against Company and Insured in federal district court, seeking a declaratory judgment that the claims alleged in the underlying action were not covered under Insured's policy with Insurer and that Insurer therefore had no obligation to defend or indemnify Insured. The district court concluded that the claims were covered by the policy and granted Company and Insured's motion for summary judgment. The Eighth Circuit Court of Appeals reversed, holding that because Company's cattle were under Insured's care, custody, and control when they were damaged, the policy did not provide coverage for Company's claimed loss. Remanded.

Lakeside appealed from the district court's grant of summary judgment in favor of Producers on Lakeside's state-law claim for fraudulent misrepresentation, negligent misrepresentation, and unjust enrichment involving payment for the feed and care of the hogs at issue. The court affirmed the district court's grant of summary judgment in favor of Producers on Lakeside's fraudulent misrepresentation claim where Lakeside was unable to establish that Producers made any false representations; affirmed the district court's grant of summary judgment on the fraudulent nondisclosure claim where Producers was under no legal obligation to disclose information to Lakeside; held that the district court did not abuse its discretion in excluding Lakeside's expert testimony where such testimony was not needed to inform the district court on the legal issues; affirmed the district court's grant of summary judgment in favor of Producers on the issue of negligent misrepresentation where Producers was not in the business or profession of supplying information or guidance to Lakeside but rather the two conducted themselves at arm's length; and held that it was not unjust to allow Producers to retain the benefit of these particular happenings when a shortfall existed, as it was not inequitable to allow a contracting party the right to fulfillment of contractual obligations, which in this case included the payment of fees contemplated by the Hog Program.

Richard Orr and Sheldon Cook had a partnership agreement to conduct a cow-calf operation. The parties sold the cows and calves in the spring of 2007. Cook received $230,935 from the sale. Orr sued Cook, disputing the reimbursement amount Cook owed him from the sale and for the cost of feeding and caring for the cows during the winter of 2007. The trial court awarded Orr $41,614. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court was not clearly erroneous in determining the value of the calves; (2) the trial court was not clearly erroneous in determining the amount of reimbursement Cook owed Orr for feed and veterinarian costs; and (3) the trial court did err in refusing to award Orr prejudgment interest because it was requested in a manner allowed by statute.