Justia Contracts Opinion Summaries

The Supreme Court reversed in part the decision of the appellate court reversing the judgment of the circuit court in favor of PML Development LLC on its action against the Village of Hawthorn Woods for breach of a development agreement between the parties and against the Village on its counterclaim for breach of the agreement, holding that the circuit court erred in granting judgment in favor of PML on the Village's breach of contract counterclaims.Following a bench trial, the circuit court found that both parties materially breached the agreement at issue but that the Village's first material breach excused PML from performing its contractual obligations. The appellate court reversed, concluding that neither the Village or PML could recover damages because each party materially breached the agreement. The Supreme Court reversed in part, holding (1) the circuit court correctly entered judgment in favor of PML on its breach of contract claims; and (2) the circuit court erred in granting judgment in favor of PML on the Village's breach of contract counterclaims. View "PML Development LLC v. Village of Hawthorn Woods" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying State Farm Mutual Automobile Insurance Company's petition for a writ of prohibition to prevent Judge Brian Edwards of the Jefferson Circuit Court from enforcing certain discovery orders, holding that State Farm was not entitled to the writ.Betty Irvin was involved in an automobile collision with Deborah Combs, who was insured by State Farm. Irvin brought suit, alleging a negligence claim against Combs and a third-party statutory bad faith claim under Kentucky's Unfair Claims Settlement Practices Act, Ky. Rev. Stat. 304.12-230, against State Farm. The trial court bifurcated the bad faith claim against State Farm from the other claims. Later, State Farm filed this petition seeking to prevent Judge Edwards from enforcing his discovery orders on the grounds that Irvin's bad faith claim against it was not yet ripe. The court of appeals denied the writ petition. The Supreme Court affirmed, holding that the court of appeals did not err. View "State Farm Mutual Automobile Insurance Co. v. Honorable Edwards" on Justia Law

The Supreme Court affirmed the opinion of the court of appeals reversing the order of the circuit court granting summary judgment in favor of Phoenix American Administrators, LLC and Phoenix American Warranty Company, Inc. in this case stemming from a contract dispute in which Plaintiff sought to recover damages from Phoenix, holding that summary judgment was prematurely granted.Phoenix was the administrator of a guaranteed asset protection waiver addendum entered into by Plaintiff during the course of his purchase of and the financing of a motor vehicle. Plaintiff sued Phoenix for breach of contract, and the trial court granted summary judgment in favor of Phoenix. The court of appeals reversed, concluding that a factual dispute existed precluding summary judgment. The Supreme Court affirmed, holding that the court of appeals did not err. View "Phoenix American Administrators, LLC v. Lee" on Justia Law

In this putative class action where Students sought a refund of money from the University of Kentucky after the University switched all on-campus classes to an online format for the remainder of the spring 2020 semester, the Supreme Court affirmed the judgment of the court of appeals affirming the trial court's ruling that governmental immunity was waived and that a breach of contract claim may proceed for adjudication on the merits, holding that the Student Financial Obligation and accompanying documents were a written contract under Ky. Rev. Stat. 45A.245(1) such that governmental immunity was waived and the underlying breach of contract claims may proceed. View "University of Ky. v. Regard" on Justia Law

The Supreme Court reversed the order of the circuit court enforcing a settlement agreement between Petitioner and Respondents, holding that the circuit court erred when it found that the parties entered into a settlement agreement by e-mail without holding a hearing on the matter.On appeal, Petitioner argued that the settlement lacked mutual assent and that the terms of the purported settlement required a written agreement. The court granted Respondents' motion to enforce the settlement agreement, finding that the parties agreed to all material terms of the agreement and formed a contract through their emails. The Supreme Court reversed, holding that the paucity of the record before the circuit court required an evidentiary hearing for the court to determine whether there was a meeting of the minds regarding the terms of the agreement. View "Levine v. Rockwool International A/S" on Justia Law

Hicks Unlimited, Inc. contracted to rent uniforms for its employees from UniFirst Corporation. The contract contained an arbitration provision stating all disputes between them would be decided by binding arbitration to be conducted "pursuant to the Expedited Procedures of the Commercial Arbitration Rules of the American Arbitration Association [AAA] and shall be governed by the Federal Arbitration Act [FAA]." A dispute arose; UniFirst moved to compel arbitration. Hicks contended the arbitration agreement was unenforceable because it did not comply with the notice requirements of South Carolina's Arbitration Act (SCAA). The circuit court denied the motion to compel arbitration, ruling the contract did not implicate interstate commerce and, therefore, the FAA did not apply. The circuit court further ruled the arbitration provision was not enforceable because it did not meet the SCAA's notice requirements. UniFirst appealed. The court of appeals reversed, holding arbitration should have been compelled because the contract involved interstate commerce and, therefore, the FAA preempted the SCAA. The South Carolina Supreme Court found that because the contract between Hicks and UniFirst did not involve interstate commerce in fact, the order of the circuit court denying UniFirst's motion to compel arbitration was affirmed, and the court of appeals' opinion was reversed. View "Hicks Unlimited v. UniFirst" on Justia Law

The Supreme Court vacated the judgment of the superior court granting Verizon New England Inc.'s motion to dismiss this complaint related to a billing dispute over a particular telephone service contract, holding that the hearing justice erred in granting Defendant's motion to dismiss, which had been converted sub silentio to a motion for summary judgment.Plaintiff filed a complaint against Verizon alleging false representation and breach of contract stemming from a billing dispute. Verizon filed a motion to dismiss under Sup. Ct. R. Civ. P. 12(b)(6). The hearing justice dismissed Plaintiff's complaint in its entirety with prejudice. The Supreme Court vacated the judgment below, holding that that issues of genuine material fact existed precluding summary judgment. View "Resmini v. Verizon New England Inc." on Justia Law

The Supreme Court vacated the judgment of Supreme Court in favor of Plaintiff Wilmington Savings Fund Society, FSB in this case involving a dispute over payments due under a promissory note relating to Defendants' mortgage, holding that summary judgment was improperly granted under the terms of this case.Plaintiff's predecessor filed a complaint against Defendants alleging breach of contract. The hearing justice granted summary judgment in favor of Plaintiff. Defendants appealed, arguing that the issue of whether Plaintiff complied with the note's notice provisions was a question of material fact precluding summary judgment. The Supreme Court vacated the judgment below, holding that Plaintiff's failure to send the notice of default to the property address referred to in the note was not in accordance with the terms of the note, and therefore, summary judgment should not have been granted. View "Wilmington Savings Fund Society, FSB v. Cavalloro" on Justia Law

After submitting the winning bid, Eagle Rock Timber, Inc. (“Eagle Rock”), contracted with Teton County, Idaho to reconstruct a stretch of road known as “Chapin Lane.” During the course of the project, Eagle Rock claimed it discovered unsuitable base material under portions of the road. Eagle Rock maintained that Teton County’s agent, Darryl Johnson, directed Eagle Rock to remove the material and said that the county would “make it right.” However, when Eagle Rock attempted to recover an amount in excess of the original Contract Price, Teton County denied Eagle Rock’s request, stating that it had not authorized any changes to the Contract. When the parties could not resolve this dispute over the amount owed, Eagle Rock filed suit. Teton County twice moved for summary judgment. The district court denied the first motion, concluding that genuine issues of material fact existed concerning whether Johnson orally waived the writing requirement and whether Johnson had authorized Eagle Rock to remove the unsuitable base material, which could support an equitable remedy. In the County's second motion, the district court granted it, ruling that since Teton County’s agent did not have actual or apparent authority to bind Teton County, the claims asserted by Eagle Rock failed as a matter of law. Eagle Rock appealed, asserting that the district court erred because there were still genuine issues of material fact that should be resolved by a jury. Further, Eagle Rock claimed the district court’s refusal to grant leave to amend its complaint to assert a separate cause of action against Johnson personally was an abuse of discretion. After review, the Idaho Supreme Court reversed the district court’s grant of summary judgment and denial of leave to amend. However, the Court affirmed the district court in not considering the ratification issue because it was beyond the scope of the pleadings at the time it was presented. View "Eagle Rock Timber, Inc. v. Teton County" on Justia Law

The Supreme Court reversed in part the judgment of the business court disposing of WW Consultants, Inc.'s (WWC) claims for contractual indemnity in favor of third-party defendants but affirmed in part as to the denial of WWC's claims for implied indemnity and contribution in favor of third-party defendants, holding that the business court erred by granting summary judgment for third-party defendants on this claim.In this case arising from a dispute involving the construction of a wastewater treatment facility in Pocahontas County, WWC, the project's design engineer, appealed the business court's rulings dismissing or granting summary judgment to three third-party defendant contractors who supplied materials for or worked on the project. The Supreme Court reversed in part, holding (1) there were material questions of fact that precluded summary judgment as to WWC's contractual indemnity claim; (2) WWC failed to plead or present facts alleging the requisite special relationships to support its implied indemnity claims; and (3) WWC failed to plead contribution claims that are recognized under the modified comparative fault statutory scheme codified at W. Va. Code 55-7-13a to -13d. View "WW Consultants, Inc. v. Pocahontas County Public Service District" on Justia Law