Justia Contracts Opinion Summaries

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.

Rudolph Slater was killed while operating a Yanmar tractor he purchased from Chris Elder Enterprises. The tractor had been manfactured by Yanmar Japan and later sold to Chris Elder Enterprises. Slater's wife, Wanda, filed a wrongful-death action against, among others, Yanmar Japan and Yanmar America, alleging claims for, inter alia, fraud, strict liability, breach of implied and express warranties, and negligence. The circuit court entered judgment in favor of Wanda, awarding her damages in the amount of $2.5 million. The Yanmar defendants appealed. The Supreme Court reversed and dismissed the case, holding (1) the circuit court lacked personal jurisdiction over Yanmar Japan, as there was no evidence to establish that Yanmar Japan had the requisite minimum contacts with the forum to warrant the exercise of general jurisdiction, and there was insufficient proof to show that personal jurisdiction could be predicated on the relationship between Yanmar Japan and its subsidiary, Yanmar America; and (2) the jury's finding that Yanmar America was negligent was not supported by substantial evidence, as Yanmar America owed no duty of care to Rudolph.

Jean Moreau & Associates brought this suit against the Health Center Commission for the County of Chesterfield (HCC), a municipal corporation, seeking a declaratory judgment and alleging claims for breach of contract and quantum meruit. The circuit court dismissed Jean Moreau's claims. The Supreme Court affirmed, holding (1) because Jean Moreau did not comply with the mandatory procedural requirements of the Virginia Public Procurement Act in bringing its breach of contract claim against HCC, the circuit court did not err in concluding that the claim was barred; and (2) the circuit court did not err in concluding that Jean Moreau's quantum meruit claim was barred by the doctrine of sovereign immunity for HCC's development and operation of Springdale, an independent living facility, because (i) municipal corporations performing governmental functions are immune from quantum meruit claims, (ii) HCC was not entitled to absolute immunity simply because it was created by a county and not a municipality, but (iii) Springdale served a governmental function.

Defendant appealed the sentence imposed after he pled guilty to being a deported alien found in the United States. Defendant contended that the government breached the plea agreement, notwithstanding the government's later admission that it made a mistake in its initial sentencing recommendation and its substitution of the recommendation to which defendant and the government had agreed in the plea agreement. The court vacated and remanded for resentencing, holding that the government breached the plea agreement and the sentence must be vacated to give defendant the benefit of his bargain, specific performance on the plea agreement.

The company, which issues preprinted travelers' checks, challenged 2010 N.J. Laws Chapter 25, amending New Jersey's unclaimed property statute, N.J. Stat. 46:30B, to retroactively reduce the period after which travelers checks are presumed abandoned from 15 years to three years, after which the funds must be turned over to the state. The district court denied an injunction. The Third Circuit affirmed, rejecting arguments under the Due Process Clause, the Contract Clause, the Takings Clause, and the Commerce Clause. The law has a rational basis. It does not substantially impairment contractual relationships; while the company has the right to use and invest TC funds until the date the TC is cashed or sold, the duration of use is further subject to the lawful abandonment period set by unclaimed property laws. The company has no investment-backed expectation with respect to the longer period of investment.The law does not directly regulate sales in other states.

In 2000, a fire destroyed a business location of Stone Flood and Fire Restoration Inc., spurring years of litigation with its insurer, Safeco Insurance Company of America. After Stone Flood and its two shareholders, James and Patrice Stone, sued Safeco in 2007, the district court dismissed all claims against Safeco. The court concluded (1) Stone Flood's claims on the insurance policy were filed three days beyond the applicable statute of limitations and were therefore barred; (2) the Stones were not insureds and lacked standing to bring individual claims under the policy; and (3) the Stones lacked standing to bring a claim of intentional infliction of emotional distress (IIED) because their alleged injuries were merely derivative of the corporation's. The Supreme Court reversed in part and affirmed in part, holding (1) the district court's calculation of the tolling of the limitations period was incorrect and a correct calculation saved Stone Flood's claims under the insurance policy; and (2) the district court properly concluded the Stones were not insureds and lacked standing to sue under the policy, and their claim of IIED failed for lack of a distinct, non-derivative injury. Remanded.

Claimant appealed from a judgment of the district court ordering the forfeiture to plaintiff United States, pursuant to 22 U.S.C. 401(a), of certain communication-jamming devices, to wit, the defendant-in-rem Jammers, owned by claimant and a company of which he was the majority shareholder and CEO. On appeal, claimant contended that the district court erred in dismissing his claim, arguing principally that the stipulation he signed was void on the grounds that it was signed under duress and without consideration. The court held that, as a matter of New York law, no consideration for claimant's agreement to the release was needed; and thus, if consideration was absent, its absence did not make the stipulation invalid. The court also held that claimant's assertions did not meet any part of the test of duress. The court further held that the district court correctly granted the government's motion to strike or for summary judgment on the ground of claimant's lack of Article III standing. Accordingly, the judgment was affirmed.