Justia Contracts Opinion Summaries

Plaintiff's son, Hayden, was involved in a near-drowning accident in which he suffered severe permanent injuries. Plaintiff subsequently sought coverage for the cost of his treatment from Wasatch Crest Mutual Insurance, under which Hayden was insured. Wasatch Crest was later declared insolvent, and Plaintiff filed a claim against the Wasatch Crest estate. The liquidator of the estate denied Plaintiff's claim, concluding that Wasatch Crest had properly terminated coverage under the language of the plan. The Supreme Court reversed, interpreting the plan in favor of coverage. Plaintiff resubmitted her claim for medical expenses to the liquidator for payment under the Utah Insurers Rehabilitation and Liquidation Act. One year later, Plaintiff filed a motion for summary judgment with the district court. The liquidator subsequently issued a second amended notice of determination denying Plaintiff's claim on the merits. The district court then denied Plaintiff's motion for summary judgment, as Plaintiff had not yet challenged the second amended notice of determination and could do so under the Liquidation Act. Plaintiff appealed the district court's order. The Supreme Court dismissed the appeal because Plaintiff did not appeal from a final judgment and had not satisfied any of the exceptions to the final judgment rule.

The Supreme Court reviewed a district court order that upheld a county court's decision that a six-year stattue of limitations did not bar Respondent Account Brokers of Larimer County, Inc.'s claim against Pettiioner Daniel Hassler. Petitioner financed the purchase of a vehicle by entering into a security agreement with Account Broker's predecessor-in-interest in which the vehicle served as collateral. Petitioner defaulted on the loan, and the predecessor repossessed the vehicle and later sold it at auction. The precedessor applied the proceeds of the auction to the balance of the loan. The proceeds were insufficient to cover the balance; thus Petitioner was still held responsible for the deficiency. The debt was eventually transferred to Account Brokers who sued Petitioner to recover the deficiency less than six years after the vehicle was sold. The county and district courts ruled in favor of Account Brokers, determining that the statute of limitations did not bar Account Brokers' claim. Upon review, the Supreme Court reversed, holding that the controlling issue was not the date that the debt was made liquidated or determinable but the date the debt accrued. "[U]nder Colorado law and the express terms of the parties' agreement, the present debt became due when it was accelerated following [the predecessor's] repossession of the vehicle and demand for full payment on the debt, which occurred more than six years before the initiation of the present suit. Accordingly, the action [was] barred by the statute of limitations."

Appellants David and Barbara Moore defaulted on the Note to their mortgage in 2008. U.S. Bank, National Association, commenced foreclosure proceedings later that year, not in its individual capacity, but solely as trustee on behalf of GSAA Home Equity Trust 2006-6 (Appellee). According to the verified petition, the Appellee was "the present holder of said Note and Mortgage having received due assignment through mesne assignments of record or conveyance via mortgaging servicing transfer." The original petition did not attach a copy of the note in question sued upon. Appellants answered, pro se in 2009, disputing all allegations and requesting that the Appellee "submit additional documentation to prove [its] claims including the representation that they were the "present holder of said Note." Appellee subsequently filed an amended petition and a second amended petition to add additional defendants. Neither of these amendments included a copy of the note. Appellee submitted its Motion for Summary Judgment to the court, again representing that it was the holder of the Note. Documentation attached to the Motion attempted to support this representation: including the Mortgage, the Note, an Assignment of Mortgage, and an Affidavit in Support of Appellee's Motion for Summary Judgment. For the first time, Appellee submitted the Note and Mortgage to the trial court. The note was indorsed in blank and contained no date for the indorsement. Appellants did not respond to Appellee's Motion, and the trial court entered a default judgment against them. The trial court entered a final judgment in favor of the Appellee. Upon review, the Supreme Court found no evidence in the record establishing that Appellee had standing to commence its foreclosure action: “[t]he trial court's granting of a default judgment in favor of Appellee could not have been rationally based upon the evidence or Oklahoma law.” The Court vacated the trial court’s judgment and remanded the case for further proceedings.

Plaintiff appealed from the district court's order dismissing his complaint against Target and Virginia Winn. Plaintiff, a Hispanic male, alleged that Winn, a white Target cashier, refused to serve him based on his race and publicly humiliated him when she turned him away from her register. Plaintiff brought suit against Winn for intentional infliction of emotional distress (IIED); against Target for vicarious liability and for negligent training, supervision, and retention; and against both defendants for violating his right to make contracts under 42 U.S.C. 1981. The district court dismissed the case, explaining that plaintiff could not maintain a section 1981 claim because he was ultimately able to complete his purchase, and that Winn's alleged actions did not rise to the level of outrageousness required to state an IIED claim under controlling Florida law. After thorough review and having had the benefit of oral argument, the court agreed and affirmed the judgment of the district court.

At issue in this case was a district court's grant of a motion for voluntary dismissal of a suit filed by Fern Peterson against Cecil and Yu Wen Davis, Kevin and Sherri Murray, David Lawrence and Private Wilderness, LLC (collectively, Private Wilderness). The issues arose from Peterson's attempt to sell property to the Davises, Murray and Lawrence. Private Wilderness asserted an easement over the property. Ultimately the case ended with the dismissal of a third-party complaint filed by Private Wilderness against Robert and Nancy Peterson (the Petersons). In resolving the appeal, the Supreme Court addressed issues raised by Private Wilderness concerning whether the district court erred when it concluded there was no prevailing party when it granted the voluntary dismissal. The Court also addressed the Petersons' cross-appeal, in which they argued that the district court erred in denying their motion for reconsideration of their I.R.C.P. 12(b)(6) and 12(c) motion to dismiss on the basis that it was moot, and by not addressing their pending summary judgment motion at the time of dismissal. Upon review, the Supreme Court vacated in part and remanded, upholding the district court's discretion concluding no prevailing party, but found the court erred by denying the motion for reconsideration.

Appellants, Leland and Ilene Haugen and Haugen Nutrition and Equipment, defaulted on promissory notes held by respondent United Prairie Bank-Mountain Lake (UPB). The various loan agreements between the parties contained provisions in which Appellants agreed to pay UPB's reasonable costs and attorney fees associated with the protection of UPB's security interests and the enforcement of Appellants' obligation to repay the loans. The district court denied Appellants' motion to submit the question of reasonable attorney fees to the jury and subsequently awarded UPB over $400,000 in attorney fees. The court of appeals affirmed, holding that UPB's claim for the recovery of attorney fees was equitable in nature and thus did not give rise to a jury trial right under the Minnesota Constitution. The Supreme Court reversed in part, holding that Appellants were constitutionally entitled to a jury determination on UPB's claim for attorney fees because the nature of the claim was contractual and the remedy sought was legal.

The town manager of the Town of Freeport signed a contract transferring the Town's emergency dispatch services to another town. Plaintiffs, two Town residents, filed an amended complaint requesting a declaratory judgment that the contract was void because it was inconsistent with section 6.10 of the Town's charter, which provides that multi-year contracts must be "made or approved by ordinance," and seeking an injunction. The Town Council later voted in favor of an ordinance that ratified the contract. The superior court subsequently dismissed the complaint, finding that the case was moot because the Town had approved the outsourcing contract by ordinance, thereby complying with section 6.10. The Supreme Court vacated the judgment and held (1) the court erred by dismissing the amended complaint because the passage of the ordinance ratifying the transfer of dispatch services contract did not render the case moot, as the contract did not conclude until the year 2016; but (2) the passage of the ordinance did satisfy the "made or approved by ordinance" requirement of section 6.10 of the charter. Remanded for entry of a judgment in favor of the Town on the merits of the amended complaint and denying the request for an injunction.

Plaintiff-Counterdefendant-Appellant David Oakes, M.D. was employed as a cardiologist by Defendant-Counterclaimant-Respondent Boise Heart Clinic Physicians, PLLC (BHC) from January 2000 until the end of July 2008, when he left to pursue other employment opportunities. While employed by BHC, Plaintiff had an employment agreement that entitled him to half the adjusted gross charges he generated. Because of his complicated arrangements with other service providers, Plaintiff's final payment was not calculated until after his departure. After his employment ended, Plaintiff corresponded with BHC regarding his final payment. Plaintiff never received payment. Instead, he received a series of letters that detailed the evolving computation of his final payment. BHC's last letter to Plaintiff included a demand for repayment. Plaintiff then sued claiming that BHC still owed him money under the employment agreement. In rendering its verdict, the jury was given a choice between three special verdict forms that corresponded with the three possible verdicts: one finding that neither party is entitled to recover from the other; one that finding that BHC owed money to Plaintiff; and one finding that Plaintiff owed money to BHC. The jury returned with a verdict in favor of Plaintiff, and against BHC, that awarded Plaintiff $2,043.92. Ultimately the district court entered a final judgment that awarded Plaintiff $2,043.92 and declared that neither party was the prevailing party for purposes of costs and attorney fees. Plaintiff appealed the "prevailing party" decision to the Supreme Court. e sought. The district court entered a judgment conferring to Oakes the amount awarded by the jury, but found that neither party was the prevailing party for purposes of costs or attorney fees. Upon review, the Supreme Court held that the district court abused its discretion by not finding Plaintiff to be the prevailing party. The case was remanded for a determination of costs and fees.

For over twenty-five years, the State required certain employees to work forty-hour weeks while requiring other employees to work only 37.5-hour weeks. Through the employees received the same biweekly paycheck, the effect of the State's policy was a disparity in actual hourly wage. The State ended the policy in 1993, but this class action was brought on behalf of those forty-hour employees. The court of appeals found (1) the merit employees were owed back pay on their statute-base claims from the day they filed their complaint or grievances until the day the State eliminated its split-pay system; and (2) the non-merit employees were owed back pay on their constitutional claims from the day the State eliminated its split-pay system and extending back approximately twenty years. The Supreme Court affirmed in part and reversed in part, holding that, under the doctrine of laches, the back pay recovery of the non-merit employees should be limited in the same manner as the court of appeals set forth for that of the merit employees.

Plaintiff sued the President of Valdosta State University, claiming that under the Due Process Clause, he was due notice of the charges, and a hearing to answer them, prior to his removal from campus. Plaintiff, a student, was removed on the ground that he presented a "clear and present danger" to the campus. Plaintiff joined the Board of Regents of the University System of Georgia as a defendant, claiming against the Board a state-law breach of contract claim for damages. Plaintiff claimed that the student handbook and contracts for student housing established binding agreements between the Board and the university students and the Board breached these agreements by failing to afford plaintiff the due process prior to his removal from campus. The court held that the district court properly denied the President's motion for summary judgment based on qualified immunity where plaintiff had a constitutional right to process before he was removed from the university and plaintiff's constitutional rights were clearly established. The court held, however, that the district court erred in failing to dismiss plaintiff's breach of contract claim against the Board as barred by the Eleventh Amendment where Georgia had not waived its Eleventh Amendment immunity for breach of contract actions.