Justia Contracts Opinion Summaries

The Alabama Space Science Exhibit Commission d/b/a U.S. Space & Rocket Center ("ASSEC") filed suit against Space Race, LLC ("Space Race"), seeking to avoid an arbitration award entered in favor of Space Race and against ASSEC by an arbitration panel in New York. In July 2016, Space Race agreed to produce an animated series for ASSEC aimed at promoting the interest of children in space exploration and science. The series was to be created and released to the public over a three-year period. In exchange, ASSEC agreed to compensate Space Race with funds ASSEC would receive from a grant from the National Aeronautics and Space Administration ("NASA"), which had contracted with ASSEC to provide funding for the series. The compensation was to be paid to Space Race annually as the series episodes were created during the three-year contract term. The parties' agreement provided that it "shall be governed" by Alabama law. Space Race produced the series before the contract term expired, but ASSEC failed to pay the amount owed for the last year of the series. Space Race claimed that ASSEC still owed Space Race approximately $1.3 million when the contract term expired. The parties' agreement contained an arbitration provision. In December 2017, after being notified by ASSEC that it would no longer make payments to Space Race because the grant from NASA had been terminated, Space Race commenced arbitration proceedings against ASSEC in New York. Space Race moved to dismiss ASSEC's Alabama action, asserting that a New York court had already entered a final judgment confirming the arbitration award. The Alabama trial court denied Space Race's motion to dismiss, and Space Race petitioned the Alabama Supreme Court for a writ of mandamus directing the trial court to dismiss ASSEC's action. Because the New York judgment confirming the arbitration award against ASSEC was entitled to full faith and credit and res judicata effect, the Supreme Court granted Space Race's mandamus petition. The trial court was directed to vacate its order denying Space Race's motion to dismiss and to enter an order granting that motion. View "Ex parte Space Race, LLC." on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of felony sexual intercourse without consent, holding that Defendant received constitutionally effective assistance of counsel.At issue was whether Defendant's trial counsel rendered ineffective assistance when counsel allowed prior consistent statements from a forensic interview into evidence without challenge. The Supreme Court affirmed, holding (1) the record before the Court implied at least a plausible justification for counsel's actions; and (2) without more evidence, it cannot be determined whether defense counsel did not perform effectively for Defendant. View "State v. Mikesell" on Justia Law

Following the outbreak of COVID-19 in early 2020, Los Angeles imposed an eviction moratorium during a “Local Emergency Period” with the stated purposes of ensuring housing security and promoting public health during the pandemic. Related provisions delay applicable tenants’ rent payment obligations and prohibit landlords from charging late fees and interest. A trade association of Los Angeles landlords, sued, alleging violations of the Constitution’s Contracts Clause.The Ninth Circuit affirmed the denial of the plaintiff’s request for preliminary injunctive relief, noting that other courts, including the Supreme Court, have recently considered various constitutional and statutory challenges to COVID-19 eviction moratoria. Under modern Contracts Clause doctrine, even if the eviction moratorium was a substantial impairment of contractual relations, the moratorium’s provisions were likely “reasonable” and “appropriate” given the circumstances of the COVID-19 pandemic. The city fairly tied the moratorium to its stated goals. The court noted that contemporary Supreme Court case law has severely limited the Contracts Clause’s potency. View "Apartment Association of Los Angeles County, Inc. v. City of Los Angeles." on Justia Law

The Court of Appeal vacated and remanded the trial court's order granting respondent's anti-SLAPP motion to strike Brighton's cross-claim for fraud. The parties' dispute stemmed from a contract between respondent and Brighton where Brighton would pay respondent $3,000 for a one-day photo shoot. Respondent filed suit against Brighton, alleging that the company failed to pay her immediately upon completion of the photoshoot. Brighton cross-complained, asserting claims for declaratory relief and fraud.The court concluded that, even if it were to assume that respondent met her burden of showing that Brighton's cross-claim for fraud arose from protected conduct, reversal is required because Brighton has shown a probability that it will prevail on its claim. In this case, the evidence submitted shows that Brighton's fraud cross-claim has the requisite minimal merit where Brighton submitted evidence that respondent made a misrepresentation when she told the company to pay LA Models for her services during the photoshoot upon receipt of an invoice rather than immediately upon her "termination" as an employee when the shoot concluded; it can be inferred that plaintiff knew that misrepresentation was false based on her actions, she intended for Brighton to rely on her misrepresentation, and Brighton justifiably did so; and reliance on respondent's misrepresentation damaged Brighton by exposing it to $90,000 in waiting-time penalties plus attorney fees and costs— in addition to the costs Brighton incurred in defending itself against her lawsuit. View "Brighton Collectibles, LLC v. Hockey" on Justia Law

The United States Court of Appeals for the Eleventh Circuit certified to three questions of law to the Georgia Supreme Court relating to a lawsuit brought in federal district court by Fife Whiteside, the trustee of the bankruptcy estate of Bonnie Winslett. Whiteside sued GEICO to recover the value of Winslett’s failure-to-settle tort claim against GEICO so that the bankruptcy estate could pay creditor Terry Guthrie, who was injured in an accident caused by Winslett. The certified questions certified asked the Supreme Court to analyze how Georgia law applied to an unusual set of circumstances that implicated both Winslett’s duty to give GEICO notice of suit and GEICO’s duty to settle the claim brought against Winslett. The Supreme Court was unable to give unqualified “yes” or “no” answers to two of the certified questions as they were posed; rather, the Court answered the questions only in the context of the circumstances of this particular case. "Winslett remains liable to Guthrie, even if her bankruptcy trustee succeeds on the failure-to-settle claim against GEICO; therefore, if the bankruptcy estate does not recover enough from GEICO to satisfy Guthrie’s judgment, the estate would not be fully compensated for Winslett’s damages, and GEICO would escape responsibility for breaching its settlement duty to Winslett. Such an outcome would deny Winslett the full measure of compensatory damages allowed under Georgia law." View "GEICO Indemnity Co. v. Whiteside" on Justia Law

The Supreme Court reversed the judgment of the court of appeals with respect to Plaintiff's constitutional claims, holding that a state university's dismissal of a student for poor academic performance does not implicate a liberty or property interest protected by the Texas Constitution's guarantee of due course of law.Plaintiff was dismissed from Texas Southern University's Thurgood Marshall School of Law after one year due to his failure to maintain the required grade point average. Plaintiff brought this suit against the School, alleging breach of contract and deprivation of his property and liberty without due course of law. The trial court granted the School's plea to the jurisdiction invoking sovereign immunity. The court of appeals reversed in part, concluding that Plaintiff's procedural and substantive due course of law claims were viable. The Supreme Court reversed in part and rendered judgment dismissing the case, holding that an academic dismissal from higher education does not implicate a protected liberty interest. View "Texas Southern University v. Villarreal" on Justia Law

The underlying class action alleged that the Illinois Department of Corrections (IDOC) unlawfully denied hearing-impaired inmates “the assistance they need to communicate effectively and participate in IDOC programs and services.” A 2018 Settlement required IDOC to screen inmates for hearing problems, refer inmates in need to a licensed audiologist for a more thorough audiological evaluation, maintain records of inmates’ evaluations, and provide inmates with care according to the results of their evaluations. For about a year after the court approved the Settlement, IDOC incorrectly referred about 700 inmates to licensed hearing instrument dispensers (LHIDs)—hearing-aid salesmen—instead of audiologists for evaluations. IDOC discontinued the practice in July 2019, based on an out-of-court agreement.In 2020, Plaintiffs moved to enforce the Settlement arguing that IDOC is not ensuring that the audiological evaluations are completed within a reasonable time period and sought attorney fees for the investigation and resolution of the LHID violations. The district court concluded that IDOC was in substantial non-compliance with the Settlement through the LHID violations,, ordered IDOC to pay about $54,000 in attorney fees, and held that the Settlement requires IDOC to ensure the audiological evaluations are completed within a reasonable timeframe, which it defined as 90 days after a referral. The Seventh Circuit affirmed with respect to attorneys’ fees. The district court incorrectly determined that IDOC was obligated to ensure that its inmates receive audiological evaluations within a set timeframe; the Settlement contains no such requirement. View "Holmes v. Godinez" on Justia Law

Plaintiff treated children in the pediatric intensive care unit of a hospital owned by VHS under his professional services agreement with PICCS, which itself operated under a separate coverage agreement with VHS. After PICCS terminated plaintiff, he filed suit alleging claims of race discrimination under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. 1981. The district court granted summary judgment dismissing plaintiff's claims against VHS.The Fifth Circuit affirmed the district court's partial final judgment, concluding that plaintiff's Title VII claim fails for lack of an employment relationship with VHS under either integrated-enterprise or joint-employment theories. The court also concluded that plaintiff's section 1981 claim fails because he cannot identify an impaired contractual right enforceable against VHS. In this case, plaintiff failed to show any contractual right enforceable against VHS under his physician agreement. View "Perry v. VHS San Antonio Partners, LLC" on Justia Law

After plaintiff prevailed on her procedural due process and breach of contract claims against TSC, the trial court vacated the jury's verdict on the breach of contract claims and reduced the damages award on her procedural due process claim to $1.The Fifth Circuit held that TSC is entitled to neither sovereign immunity under the United States Constitution nor governmental immunity under state law. In this case, the Texas Legislature abrogated TSC's governmental immunity such that plaintiff could bring state law breach of contract claims against TSC. Therefore, the argument that the Texas Legislature attempted to limit federal jurisdiction over these claims is unavailing. The court also held that it was not required to address TSC's alternative arguments and declined to do so. The court reversed the dismissal of plaintiff's breach of contract claims, reinstated the jury's verdict on those claims, and remanded for the district court to consider TSC's alternative arguments regarding whether sufficient evidence supports plaintiff's breach of contract claims. The court affirmed the district court's grant of judgment as a matter of law on the due process violation damages and reduction of the jury's award of $12,500,000 to the nominal amount of $1. The court reversed the district court's vacatur of the portion of the attorneys' fees award based on the breach of contract claims and remanded for the district court to address TSC's alternative arguments regarding those claims and to determine whether plaintiff is entitled to attorneys' fees and in what amount. View "Tercero v. Texas Southmost College District" on Justia Law

After the University terminated her employment as the head coach of the women's basketball team, plaintiff filed suit alleging violations of Title VII of the Civil Rights Act of 1964 and Title IX of the Education Amendments of 1972, as well as state-law claims for breach of contract, breach of the implied covenant of good faith and fair dealing, and invasion of privacy.The Fifth Circuit affirmed the district court's judgment as to the breach of contract and Title IX claims. The court concluded that judgment in favor of plaintiff on the breach of contract claim was proper where a reasonable jury could have concluded that plaintiff's management of funds did not give the University cause to terminate her employment. Furthermore, the University was not entitled to a new trial on plaintiff's breach of contract claim. In this case, the district court did not abuse its discretion in refusing to provide the requested jury instruction and any error on the district court's part was harmless. In regard to the Title IX claim, the court concluded that denial of plaintiff's jury instruction was not an abuse of discretion or grounds for a new trial. However, the court reversed the district court's judgment as to the privacy claim and concluded that it failed as a matter of law. The court explained that the facts disclosed by the University were of legitimate concern to the public and the district court clearly erred in concluding otherwise. View "Taylor-Travis v. Jackson State University" on Justia Law