Justia Contracts Opinion Summaries

Current or former Uber drivers from different states agreed to Uber’s “Technology Services Agreement” as a condition of using Uber’s platform. The agreement requires drivers to resolve disputes with Uber on an individual basis through final and binding arbitration. Drivers may opt-out by sending Uber an email or letter. Singh’s class action alleged Uber had violated New Jersey wage and hour laws by misclassifying drivers as independent contractors, failing to pay them the minimum wage, and failing to reimburse them for business expenses. Calabrese’s class action, which was joined to Singh’s, sought to proceed collectively under the Fair Labor Standards Act.The district court ruled in Uber’s favor, compelling arbitration, having defined the relevant class as Uber drivers nationwide. The court found that interstate "rides constitute just 2% of all rides, resemble in character the other 98% of rides, and likely occur due to the happenstance of geography” for purposes of the exception in the Federal Arbitration Act (FAA) for arbitration agreements contained in the “contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce,” 9 U.S.C. 1. The Third Circuit affirmed. The drivers' work is centered on local transportation. Most Uber drivers have never made an interstate trip. When Uber drivers do cross state lines, they do so only incidentally. They are not “engaged in foreign or interstate commerce.” View "Singh v. Uber Technologies, Inc" on Justia Law

The assignees of two Medicare Advantage Organizations seek reimbursements from insurance companies that they allege qualify as primary payers of beneficiaries’ medical expenses. The insurance companies argued, and the district courts agreed, that the assignees’ claims are barred because both assignees failed to satisfy a procedural requirement: a contractual claims-filing deadline in one case and a statutory requirement of a pre-suit demand in the other. The assignees contend that the procedural requirements are preempted by the Medicare Secondary Payer Act.   The Eleventh Circuit affirmed. The court reasoned that Florida’s pre-suit demand requirement does not meet this relatively high bar. The statutory notice requirement and corresponding 30-day cure period are procedural requirements that may result in a brief delay. But the Florida law does not prevent or meaningfully impede the reimbursement of Medicare Advantage Organizations that Congress sought to facilitate. So, the provision does not create an unconstitutional obstacle to the purposes or operation of the Medicare Secondary Payer Act. View "MSP Recovery Claims, Series LLC v. United Automobile Insurance Company" on Justia Law

G Companies Management, LLC, a California limited liability company, appealed an order staying its cross-complaint against LREP Arizona, LLC, based on the forum selection clause in a loan agreement between the parties. The cross-complaint alleged multiple causes of action, all based on the assertion that the interest rates charged in the loan agreement were usurious under California law, and G Companies contended the trial court erred because a forum selection clause was not enforceable if doing so would deprive a California resident of the protections of the state's fundamental public policy. The trial court held enforcement of the selection clause was appropriate because: (1) the loan transaction was substantially related to the chosen forum (Arizona); and (2) California had a complicated relationship with usury and allowed unlimited interest rates to be charged in numerous circumstances. LREP contended the court’s decision was correct because the “many exceptions” to California’s interest rate limits demonstrate that the prohibition of usury “is not a fundamental policy” in California. To this, the Court of Appeal disagreed and therefore reversed. "By virtue of its inclusion in article XV, section 1, of our Constitution, and because it cannot be waived, we find that California’s usury law does reflect a significant public policy. It prohibits money lending at rates higher than specified, even while recognizing numerous exceptions to those rate limitations. The complexity of the law does not imply a lack of commitment to the policy. To the contrary, such a fine-tuned approach suggests that significant effort has gone into determining the circumstances under which interest rate limitations are necessary for the protection of Californians." View "G Companies Management, LLC v. LREP Arizona LLC" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing certain defendants for lack of personal jurisdiction, holding that the defendants' contacts were too attenuated for them to have purposefully established minimum contacts within Nebraska.The out-of-state defendants at issue on appeal facilitated the sale of allegedly defective software installed by a local mechanic in four of Plaintiff's trucks. Plaintiff asserted against them claims for strict liability, negligence, and breach of implied warranties. The district court granted the defendants' motion to dismiss, concluding that Plaintiff failed to make a prima facie showing of jurisdiction. The Supreme Court affirmed, holding that the quality and nature of the defendants' activities related to this action did not support personal jurisdiction. View "Wheelbarger v. Detroit Diesel ECM, LLC" on Justia Law

Section 20.5 of North Carolina’s 2017 Farm Act contains provisions making it illegal to enter into two types of contractual agreements: (1) any settlement agreement conditioned on an agricultural producer’s union affiliation (the Settlement Provision) and (2) any agreement that would require an agricultural producer to process dues checkoffs for its farmworker-employees (the Dues Provision). The Farm Labor Organizing Committee and others (collectively, FLOC) contend that these prohibitions violate the First Amendment, Fourteenth Amendment, and 42 U.S.C. Section 1981. FLOC initiated this action against the Attorney General of North Carolina and the Governor of North Carolina (collectively, the State). The district court held that the Settlement Provision violated the Constitution and so enjoined it, but upheld the constitutionality of the Dues Provision, and then held that neither provision violated Section 1981.   The Fourth Circuit reversed the judgment of the district court as to the Settlement Provision and vacated the accompanying injunction, but affirmed in all other respects. The court explained that a rational basis supports Section 20.5. Agriculture is North Carolina’s largest industry, which makes it a subject of great interest for state legislators. The state also embraces its right-to-work policies and has worked repeatedly to strengthen them. In addition to these general bases for enacting Section 20.5, both challenged provisions respond to discrete legislative concerns. Further, the Settlement Provision prohibits parties from conditioning a settlement agreement on an agricultural producer’s union affiliation. Thus, the court rejected the broad reading advanced by FLOC and adopted by the district court that this statutory provision bars any settlement agreement between an agricultural producer and labor union. View "Farm Labor Organizing Committee v. Joshua Stein" on Justia Law

The Supreme Court affirmed in part and reversed in part and remanded this matter for a new trial, holding that the district court erred in proceeding to a trial without a jury on Plaintiff's causes of action for breach of contract, breach of guaranty, and unjust enrichment.Plaintiff's brought this complaint against Defendants for, among other causes of action, forcible entry and detainer. The district court granted relief on the forcible entry and detainer claim, ordering restitution. After a bench trial, the district court heard the remaining causes of action and awarded damages to Plaintiff. The Supreme Court reversed in part, holding (1) Plaintiff's remaining causes of action were legal in nature, and the issues of fact that arose thereunder entitled Defendants to a jury trial unless waived; and (2) there was no waiver of Defendants' right to a jury trial. View "132 Ventures, LLC v. Active Spine Physical Therapy, LLC" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court granting a directed verdict on a bad faith claim, holding that Wittmer v. Jones, 864 S.W.2d 885, 890 (Ky. 1993), established the applicable legal standard for both common law and statutory bad-faith claims.Cincinnati Insurance Company (CIC) brought a declaratory judgment action disputing coverage under a commercial general liability policy insuring K-2 Catering, LLC for claims Haley Belt made stemming from an accident that occurred during an event hosted by K-2's member-managers at their residence. Ultimately, judgment was entered declaring coverage under the policy. While the action was pending, Belt brought a separate action against K-2 and CIC, alleging bad faith and negligence in the settlement of her claims under K-2's policy. The negligence claims were settled and, after a jury trial, the jury returned a verdict against CIC. The court of appeals reversed, concluding that the trial court erred when it failed to grant CIC a directed verdict on the bad faith claims. The Supreme Court affirmed, holding that the trial court erred when it failed to apply the Wittmer standard and grant a directed verdict for CIC. View "Belt v. Cincinnati Insurance Co." on Justia Law

Defendants used fake driver’s licenses and a false tissue procurement company as cover to infiltrate conferences that Planned Parenthood hosted or attended. Using the same strategy, defendants also arranged and attended lunch meetings with Planned Parenthood and visited Planned Parenthood health clinics. During these conferences, meetings, and visits, defendants secretly recorded Planned Parenthood staff without their consent. After secretly recording for roughly a year-and-a-half, Defendants released on the internet edited videos of the secretly recorded conversations. After a jury trial, the district court entered judgment in favor of Planned Parenthood and awarded it statutory, compensatory, and punitive damages as well as limited injunctive relief.   The Ninth Circuit affirmed in part and reversed in part the district court’s judgment, after a jury trial, in favor of Planned Parenthood Federation of America, Inc., and other plaintiffs on claims of trespass, fraud, conspiracy, breach of contracts, unlawful and fraudulent business practices, violating civil RICO, and violating various federal and state wiretapping laws. Affirming in part, the panel held that the compensatory damages were not precluded by the First Amendment. The panel held that under Cohen v. Cowles Media Co., 501 U.S. 663 (1991), and Animal Legal Def. Fund v. Wasden, 878 F.3d 1184 (9th Cir. 2018), facially constitutional statutes apply to everyone, including journalists. The panel reversed the jury’s verdict on the claim under the Federal Wiretap Act, 18 U.S.C. Section 2511(2)(d), and vacated the related statutory damages for violating this statute. View "PLANNED PARENTHOOD FEDERATION, ET AL V. CENTER FOR MEDICAL PROGRESS, ET AL" on Justia Law

The Supreme Court affirmed the judgment of the superior court dismissing this action under Indiana Trial Rule 12(B)(6) but modified the judgment to reflect that the dismissal was without prejudice, holding that the church-autonomy doctrine applied in this case and required its dismissal under Rule 12(B)(6).Plaintiff sued the Roman Catholic Archdiocese of Indianapolis, Inc., asserting intentional interference with his contract and employment with Cathedral High School. The Archdiocese moved to the dismiss the complaint and invoked three defenses under the First Amendment, including the church-autonomy defense. The trial court dismissed the case with prejudice for failure to state a claim and for lack of subject-matter jurisdiction. The Supreme Court affirmed, holding that dismissal under Rule 12(B)(1) was improper but that the church-autonomy doctrine barred Plaintiff's claims. View "Payne-Elliott v. Roman Catholic Archdiocese of Indianapolis, Inc." on Justia Law

Plaintiff Crystal Point Condominium Association, Inc. obtained default judgments against two entities for construction defect claims. Kinsale Insurance Company was alleged to have insured those entities, under the Direct Action Statute, N.J.S.A. 17:28-2. The relevant policies both contained an arbitration agreement providing in part that “[a]ll disputes over coverage or any rights afforded under this Policy . . . shall be submitted to binding Arbitration.” Crystal Point filed a declaratory judgment action against Kinsale, alleging that it was entitled to recover the amounts owed by the entities under the insurance policies issued by Kinsale. Kinsale asserted that Crystal Point’s claims were subject to binding arbitration in accordance with the insurance policies. Kinsale argued that the Direct Action Statute did not apply because Crystal Point had not demonstrated that neither entity was insolvent or bankrupt. In the alternative, Kinsale contended that even if the statute were to apply, it would not preclude enforcement of the arbitration provisions in the policies. The trial court granted Kinsale’s motion to compel arbitration, viewing the Direct Action Statute to be inapplicable because there was no evidence in the record that either insured was insolvent or bankrupt. An appellate court reversed the trial court’s judgment, finding the evidence that the writs of execution were unsatisfied met the Direct Action Statute’s requirement that the claimant present proof of the insured’s insolvency or bankruptcy and determining that the Direct Action Statute authorized Crystal Point’s claims against Kinsale. The appellate court concluded the arbitration clause in Kinsale’s insurance policies did not warrant the arbitration of Crystal Point’s claims, so it reinstated the complaint and remanded for further proceedings. The New Jersey Supreme Court determined Crystal Point could assert direct claims against Kinsale pursuant to the Direct Action Statute in the setting of this case. Based on the plain language of N.J.S.A. 17:28-2, however, Crystal Point’s claims against Kinsale were derivative claims, and were thus subject to the terms of the insurance policies at issue, including the provision in each policy mandating binding arbitration of disputes between Kinsale and its insureds. Crystal Point’s claims against Kinsale were therefore subject to arbitration. View "Crystal Point Condominium Association, Inc. v. Kinsale Insurance Company " on Justia Law