Justia Contracts Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint seeking an order prohibiting the general division judge from exercising further authority over some of the claims in the underlying case, holding that the court of appeals properly dismissed the complaint.Appellant brought an action against the estate of his ex-wife in the general division of the court of common pleas seeking to recover funds to which Appellant claimed he was entitled under the former spouses' separation agreement. The state filed a counterclaim against Appellant. The trial court ruled (1) Appellant was entitled to $15,353, but there were genuine issues that precluded summary judgment on his remaining claims; and (2) the estate was entitled to partial summary judgment on its counterclaims. Appellant then filed a complaint for a writ of prohibition seeking to prevent the judge from taking further action on the estate's counterclaim. The court of appeals dismissed the complaint. The Supreme Court affirmed, holding that the general division did not patently or unambiguously lack subject-matter jurisdiction, and Appellant had an adequate legal remedy by way of direct appeal. View "State ex rel. Gray v. Kimbler" on Justia Law

Plaintiff sued Farmers New World Life Insurance Company (Defendant or Farmers) for breach of contract, breach of the covenant of good faith and fair dealing, and punitive damages in connection with a policy insuring the life of her ex-husband. The trial court granted summary judgment for Defendant on those claims, concluding it was undisputed that the ex-husband remained the owner of the policy until he died, and that he had changed the beneficiaries on the policy, reducing his ex-wife’s interest from 100 percent to 25 percent.   The Second Appellate District reversed, finding that the trial court failed to consider the terms of a divorce decree affecting ownership of the policy, and because Defendant’s agent repeatedly assured Plaintiff, up to and after the ex-husband’s death, that Plaintiff remained the sole beneficiary. Therefore, the court concluded disputed issues of material fact prevent summary judgment. View "Randle v. Farmers New World Life Insurance Co." on Justia Law

Uniloc brought multiple infringement suits against Google concerning patents directed to innovations in multimedia content delivery, IT security, high-resolution imaging, network connectivity, video conferencing, and image and text searching. Google alleged Uniloc lacked standing because its predecessors had granted Fortress a license and an unfettered right to sublicense to the asserted patents as part of a financing arrangement. Uniloc argued that any license had been eliminated by a Termination Agreement executed between Uniloc’s predecessors and Fortress before the suits commenced.The district court dismissed, finding that a license had been granted and survived the Termination Agreement. The Federal Circuit reversed. The district court erred in interpreting the Termination Agreement. The License Agreement granted Fortress a “non-exclusive, transferrable, sub-licensable, divisible, irrevocable, fully paid-up, royalty-free and worldwide license” to several of Uniloc’s patents, including those at issue. The Termination Agreement stated that the License Agreement “shall terminate and shall be of no further force or effect without any further documentation or action and without liability to any party hereto, and the rights of each of the applicable parties under the applicable agreement shall terminate.” By terminating the License Agreement and rights under that agreement, the Termination Agreement terminated Fortress’s license. Although the License Agreement describes the license as “irrevocable” the context clearly refers to the license’s being “irrevocable” by the licensor and does not preclude revocation by mutual agreement. View "Uniloc 2017 LLC v. Google LLC" on Justia Law

In these consolidated appeals arising from the district court's grant of summary judgment in favor of Triangle Cayman Asset Company and Oriental Bank in a foreclosure action brought by Triangle against Appellants, who brought counterclaims against Triangle and brought in Oriental as a third party defendant, the First Circuit held that remand was required for further proceedings.While the procedural history of this case was complex, the First Circuit held, ultimately, that (1) several aspects of the appeals here as to Triangle were moot and required dismissal; (2) the district court did not err in dismissing the breach of contract and fraud counterclaims against Triangle; (3) the district court did not err in entering summary judgment in favor of Oriental; and (4) as to appeal number three, in which Appellants challenged the district court's judgments entered on January 3, 2020, the judgments were void. View "Triangle Cayman Asset Co. v. LG & AC, Corp." on Justia Law

The First Circuit affirmed the judgment of the district court appointing a receiver in an interlocutory appeal occurring during litigation between solar energy companies and the bank that funded the companies' development and expansion, holding that the district court did not abuse its discretion when it granted the bank's motion to appoint a receiver.The companies filed an amended complaint against the bank claiming that the bank breached certain contracts with the companies. The bank, in turn, initiated a federal action against the companies alleging breach of contract and other claims. The companies filed an answer and asserted several counterclaims, including claims based on the same allegations as in the other case. After consolidating the two cases the district court granted the bank's motion for the appointment of a receiver. The First Circuit affirmed, holding that the district court did not abuse its discretion when it granted the bank's motion to appoint a receiver. View "Green Earth Energy Photovoltaic Corp. v. Keybank National Ass'n" on Justia Law

The First Circuit affirmed the decision of the district court entering summary judgment in favor of Defendants on Plaintiffs' claims for breach of contract and other related causes of action, holding that the district court properly granted summary judgment in Defendants' favor.Plaintiff and Defendants negotiated the terms of a stock transfer agreement (STA) through an exchange of emails. Later, Defendants terminated the STA pursuant to the contract's termination clause, and Plaintiff sued. The district court entered summary judgment for Defendants, concluding (1) no enforceable contract had been formed, and (2) even if the STA constituted an enforceable contract, Defendants properly exercised their right of termination. The First Circuit affirmed, holding (1) Defendants' properly exercised their termination right; and (2) Plaintiffs' two alternative theories of recovery were unavailing. View "FinSight I LP v. Seaver" on Justia Law

Jernigan Copeland Attorneys, PLLC (JCA), a law firm practicing out of Ridgeland, Mississippi, filed suit against Shad White, in his official capacity as auditor for the state of Mississippi, seeking to recover damages for services rendered and for the reimbursement of costs and expenses owed to a public relations firm. A circuit court found that, because discovery had not been completed in the case, genuine issues of material fact remained. Thus, it denied the office of the state auditor’s (OSA) motion to dismiss or, alternatively, for summary judgment. Because JCA failed to submit evidence creating a genuine issue of material fact that the employment contract complied with statutory requirements, and because JCA’s alternative claims were barred by the applicable statute of limitations, the Mississippi Supreme Court reversed the trial court’s denial of summary judgment. View "White v. Jernigan Copeland Attorneys, PLLC" on Justia Law

Neurosurgeon Donald Blaskiewicz, M.D. went to work for the Spine Institute of Idaho (the “Spine Institute” or the “Institute”) in 2018. The Spine Institute entered into a Professional Services Agreement (the PSA) with Blaskiewicz containing a non-compete clause, contractually proscribing Blaskiewicz from practicing medicine within fifty miles of the Spine Institute’s office (with an explicit exception for Caldwell) for a period of eighteen months, should his employment with the Spine Institute be terminated for any reason. Pursuant to the PSA, Blaskiewicz had two ways to avoid the non-compete clause: he could either get permission from the Spine Institute to practice medicine within the proscribed area, or he could pay the Spine Institute $350,000 in “liquidated damages.” The PSA also required any disputes to be resolved by arbitration. Less than a year and a half after hiring Blaskiewicz, the Spine Institute terminated his employment. Blaskiewicz filed suit in district court, seeking a declaratory judgment that the non-compete clause was unenforceable. The district court concluded that the non-compete clause was against public policy and void as a matter of law, and granted summary judgment in favor of Blaskiewicz. The Idaho Supreme Court reversed, finding the district court did not cite or analyze the statutes governing non-compete agreements in Idaho. The Court concluded there were genuine issues of material fact such that summary judgment was inappropriate as to whether the non-compete provision was void as a matter of public policy or otherwise enforceable. View "Blaskiewicz v. Spine Institute of Idaho" on Justia Law

Defendants used fake driver’s licenses and a false tissue procurement company as cover to infiltrate conferences that Planned Parenthood hosted or attended. Using the same strategy, defendants also arranged and attended lunch meetings with Planned Parenthood and visited Planned Parenthood health clinics. During these conferences, meetings, and visits, defendants secretly recorded Planned Parenthood staff without their consent. After secretly recording for roughly a year-and-a-half, Defendants released on the internet edited videos of the secretly recorded conversations. After a jury trial, the district court entered judgment in favor of Planned Parenthood and awarded it statutory, compensatory, and punitive damages as well as limited injunctive relief.   The Ninth Circuit affirmed in part and reversed in part the district court’s judgment, after a jury trial, in favor of Planned Parenthood Federation of America, Inc., and other plaintiffs on claims of trespass, fraud, conspiracy, breach of contracts, unlawful and fraudulent business practices, violating civil RICO, and violating various federal and state wiretapping laws. Affirming in part, the panel held that the compensatory damages were not precluded by the First Amendment. The panel held that under Cohen v. Cowles Media Co., 501 U.S. 663 (1991), and Animal Legal Def. Fund v. Wasden, 878 F.3d 1184 (9th Cir. 2018), facially constitutional statutes apply to everyone, including journalists. The panel reversed the jury’s verdict on the claim under the Federal Wiretap Act, 18 U.S.C. Section 2511(2)(d), and vacated the related statutory damages for violating this statute. View "PLANNED PARENTHOOD FEDERATION, ET AL V. CENTER FOR MEDICAL PROGRESS, ET AL" on Justia Law

Plaintiffs in this class action are a class of all West Virginia citizens who refinanced a total of 2,769 mortgages with Defendant Quicken Loans Inc. (now Rocket Mortgage, LLC) from 2004 to 2009, for whom Quicken Loans obtained appraisals from Defendant appraisal management company Title Source, Inc. (now Amrock Inc.) using a request form that included an estimate of value of the subject property. The district court certified the proposed class and granted summary judgment to Plaintiffs on three claims: unconscionable inducement under West Virginia Code Section 46A-2-121(a)(1); breach of contract; and conspiracy.   Previously the Fourth Circuit concluded that Plaintiffs had standing because all of the class members had paid “for independent appraisals that . . . they never received”. Three months later, the Supreme Court issued its opinion in TransUnion LLC v. Ramirez, which addressed Article III standing in the context of a class-action case. Having considered the parties' submissions, the Fourth Circuit concluded that the district court should apply TransUnion to the facts of this case in the first instance. Accordingly, the court vacated and remanded for further proceedings. View "Phillip Alig v. Rocket Mortgage, LLC" on Justia Law