Justia Contracts Opinion Summaries

Plaintiff, a citizen of India, worked as a crew member on the Stargate, a merchant ship managed by the Singapore-based shipping company Eastern Pacific. Plaintiff brought suit against Eastern Pacific in the Eastern District of Louisiana, alleging tort claims under the Jones Act and general maritime law, as well as contract claims arising from a collective bargaining agreement. In March 2020—after Plaintiff brought his complaint and Eastern Pacific consented to federal court jurisdiction, but before Plaintiff perfected service—Eastern Pacific sued Plaintiff in Goa, India. In the Indian suit, Eastern Pacific sought an anti-suit injunction to prevent Plaintiff from litigating in American court. Plaintiff sought an anti-suit injunction to prohibit Eastern Pacific from prosecuting its Indian suit against him. Finding the Indian litigation vexatious and oppressive and determining that it need not show comity to the Indian court that had attempted to enjoin the American suit, the district court granted the injunction in favor of Plaintiff. Eastern Pacific appealed the district court’s grant of the anti-suit injunction.   The Fifth Circuit affirmed, holding that there is no basis to conclude that the district court abused its discretion in granting the anti-suit injunction. The court reasoned that the district court was well within its discretion to conclude that the vexatiousness of the Indian litigation outweighed any comity concerns. View "Ganpat v. Eastern Pacific Shipping" on Justia Law

The Supreme Court reversed the judgment of the court of appeals in this contract dispute, holding that the court of appeals erred by failing to apply a common-law default rule to the parties' dispute involving the sale of working interests in 109 oil-and-gas leases.According to the Court, Texas cases have long followed a default common-law rule in the circumstances that the words "from" or "after" a specific date to measure a length of time. Under the rule, courts must treat the time period as excluding the specified date (measuring date), and therefore, a period measured in years "from" or "after" a measuring date ends on the anniversary of the measuring date, not the day before. In the instant case, the parties asked the Supreme Court to resolve key issues of contract construction. Noting that the parties could have easily departed from the default rule by indicating as much within the four corners of the relevant lease, the Supreme Court held that because the parties' agreement implicated the default rule without displacing it, the default rule must be applied to the dispute. View "Apache Corp. Apollo Exploration, LLC" on Justia Law

The Santa Ynez Band of Chumash Mission Indians of the Santa Ynez Reservation California (Chumash) appealed a judgment following the granting of a motion for summary judgment in favor of Lexington Insurance Company (Lexington) in Chumash’s lawsuit against Lexington for denial of insurance coverage.   The Second Appellate District affirmed. The court concluded that, among other things, Chumash did not present sufficient evidence to show that the COVID-19 virus caused physical property damage to its casino and resort so as to fall within the property damage coverage provisions of the Lexington insurance policy. The court explained that had the Chumash Casino and Resort sustained property damage, it was required to specify what property was damaged and to submit a claim for the dollar amount of that loss. The absence of such information supports Lexington’s decision to deny coverage. View "Santa Ynez Band of Chumash etc. v. Lexington Ins. Co." on Justia Law

While working for Adnet, Inc. (“Adnet”), Defendants learned of a subcontract that Adnet was attempting to win. Thereafter, Defendants, through their own company, submitted a bid for that same subcontract. After Defendants won the subcontract, Adnet brought claims against them for breach of the duty of loyalty, tortious interference with a business relationship, and business conspiracy. The district court granted Defendants’ motion for summary judgment, concluding that Defendants did not compete against Adnet, that Adnet did not have a business expectancy in the subcontract, and that, without proof of an underlying tort, there was no business conspiracy. Adnet appealed.   The Fourth Circuit reversed the district court’s grant of summary judgment to Defendants on Adnet’s claims for breach of the duty of loyalty and tortious interference with a business relationship. Further, the court vacated the district court’s grant of summary judgment to Defendants on Adnet’s business conspiracy claim and remanded. The court explained that there is sufficient evidence of a direct competition for the subcontract between Adnet and Defendants while they were working for Adnet to bar a grant of summary judgment to Defendants. A reasonable juror could conclude that employees, like Defendants, breach their duty of loyalty to their employer when they learn of a potential business opportunity through their employment and then participate in direct competition with their employer for that opportunity while still employed. View "Adnet, Inc. v. Rohit Soni" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal in this action alleging that Defendants entered into a lease-leaseback construction agreement in violation of various statutes and common law rules, holding that the specific lease-leaseback arrangement at issue in this case was not a "contract" within the meaning of Cal. Gov. Code 53511.Plaintiff brought this action alleging that the Fresno Unified School District and Harris Construction Co. entered into an unlawful lease-leaseback construction agreement. At issue before the Supreme Court was whether a lease-leaseback arrangement in which construction is financed through bond proceeds, rather than through the builder, is a "contract" within the meaning of section 53511. The Supreme Court held that the lease-leaseback arrangement in this case was not a "contract" under the statute because (1) the underlying project was fully funded by a prior sale of general obligation bonds and payment of the debt service on the bonds was from ad valorem property taxes; and (2) therefore, payment did not dependent on the lease-leaseback arrangement or on completion of the project. View "Davis v. Fresno Unified School District" on Justia Law

The Court of Appeals affirmed the judgment of the Appellate Division dismissing Plaintiffs' claims that Taxi and Limousine Commission and New York City breached the implied covenant of good faith and fair dealing and engaged in deceptive business practices under N.Y. Gen. Bus. Law 349, holding that Plaintiffs failed to state a claim.Plaintiffs, entities that purchased government licenses to operate taxis at an auction, brought this action alleging that Defendants (1) breached the implied covenant of good faith and fair dealing by failing to enforce certain licensing requirements against smartphone applicate-based competitors such as Uber Technologies, Inc. and Lyft, Inc.; and (2) engaged in deceptive business practices in their promotion of the auction. Supreme Court granted in part Defendants' motion to dismiss. The Appellate Division reversed in part and concluded that both claims should be dismissed. The Court of Appeals affirmed, holding (1) Plaintiffs did not adequately plead a claim for breach of the implied covenant of good faith and fair dealing; and (2) Plaintiffs failed to plead the type of conduct covered by N.Y. Gen. Bus. Law 349. View "Singh v. City of New York" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the order of the circuit court failing to rule on Plaintiffs' contract claim, holding that the court of appeals correctly found that Plaintiffs waived their breach of contract claim.Plaintiffs, who leased property owned by Defendants, brought this action alleging wrongful eviction, breach of contract, and defamation. The trial court granted summary judgment to Defendants on the wrongful eviction claim and then dismissed Plaintiffs' defamation claims. The court of appeals affirmed and ruled that Plaintiffs waived their breach of contract claim. The Supreme Court affirmed, holding that the court of appeals correctly held that Plaintiffs waived their contract claim. View "Wieland v. Freeman" on Justia Law

Plaintiff, an African American woman, worked as a conductor for Amtrak National Railroad Passenger Corporation (Amtrak). During her employment, she belonged to a division of the Sheet Metal, Air, Rail and Transportation Workers (SMART) union, which maintained a collective bargaining agreement (CBA) with Amtrak. Plaintiff brought the instant lawsuit pro se. She named Amtrak and the company’s director of employee relations as Defendants, along with three other Amtrak colleagues. Plaintiff asserted state-law claims of breach of contract and tort, as well as a federal claim of racial discrimination in violation of Title VII. Defendants moved to dismiss, and Plaintiff moved for summary judgment as well as for leave to amend her complaint. The district court granted Defendants’ motion and denied Plaintiff’s two motions. The district court held that Plaintiff’s claims were subject to arbitration under the Railway Labor Act (RLA).   The Fourth Circuit affirmed. The court explained that it declines to unwind a statutory scheme without a clear congressional directive to do so. Plaintiff argued that at least her particular claim is not a minor dispute. The mere fact that Plaintiff’s claim arises under Title VII does not disqualify that claim from being a minor dispute within the RLA’s ambit. The thrust of Plaintiff’s Title VII claim is that Amtrak deviated from its policies when dealing with her. While Plaintiff’s allegations as to her own treatment are factual, those concerning Amtrak’s policies directly implicate the relevant CBA between Plaintiff’s union, SMART, and Amtrak. That some of Plaintiff’s interpretive disagreements concern the Drug-Free Program does not alter the character of her claim. View "Dawn Polk v. Amtrak National Railroad Passenger Corporation" on Justia Law

Plaintiff was a subcontractor for Forney Enterprises, a contractor working for the Pentagon. Forney Enterprises was bonded through the Fidelity and Deposit Company of Maryland. Plaintiff worked as a project manager for Forney Enterprises, supervising others who engaged in manual labor. After Forney Enterprises’ work at the Pentagon was terminated, Plaintiff sued Fidelity to recover the value of the work he had not been paid for. The district court found that his supervisory work did not qualify as “labor” and granted summary judgment for Fidelity.   The Fourth Circuit affirmed. The court explained that Under the Miller Act, contractors hired to work on government projects are required to furnish bonds to pay those who provided labor and were not paid as a result of a dispute. But not all work on a government project qualifies as “labor” under the Miller Act. And even when the work qualifies as labor, to claim his piece of the bond, a laborer must sue within one year of completing the labor to recover. Here, the court found that much of Plaintiff’s work was “labor,” the only work he performed within one year of filing suit, a materials inventory, was not “labor.” And no circumstances warrant estopping Fidelity from asserting the statute of limitations. View "Elliot Dickson v. Fidelity and Deposit Company" on Justia Law

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