Justia Contracts Opinion Summaries

The Supreme Court conditionally granted mandamus relief in this arbitration dispute, holding that the trial court abused its discretion in determining that pre-arbitration discovery was warranted in this case.After Plaintiff's employment was terminated she sued Defendant, her former employer, claiming discrimination and retaliation. Defendant moved to compel arbitration pursuant to the company's employee handbook acknowledgment and agreement, which contained an arbitration agreement. At issue was Plaintiff's second motion to compel pre-arbitration discovery claiming that an enforceable arbitration agreement did not exist. After the trial court granted the motion Defendant sought mandamus relief. The court of appeals denied the motion. The Supreme Court conditionally granted mandamus relief, holding that the trial court clearly abused its discretion in ordering pre-arbitration discovery because Plaintiff failed to provide the trial court with a reasonable basis to conclude that it lacked sufficient information to determine whether her claims were arbitrable. View "In re Copart, Inc." on Justia Law

The Supreme Court affirmed in part and reversed in part the trial court's decision resolving all issues in this oil and gas dispute favorably to the lessors of a mineral lease and awarding damages for underpayment of royalties, holding that remand was required to determine damages, if any, for off-premises compressor-fuel use.One lease provision in this case required the lessee to "compute and pay royalties on the gross value received." The other lease provision at issue required royalties to be "computed at the end of the mouth of the well." The Supreme Court affirmed the lower courts' judgments except as to the portion of the judgment awarding damages for royalties on compressor fuel, holding (1) the lower courts correctly concluded that the lessee's deduction of postproduction costs was in error because the mineral lease explicitly resolved the conflict in favor of a gross-proceeds calculation; and (2) because the compressor-fuel damages were not conclusively established in the amount awarded, remand was required. View "BlueStone Natural Resources II, LLC v. Randle" on Justia Law

The Supreme Court affirmed the decision of the district court granting Defendants' motion for summary judgment and dismissing Plaintiff's claims for negligent misrepresentation, fraudulent misrepresentation, and breach of contract, holding that Plaintiff's claims were subject to the two-year statute of limitations set forth in Iowa Code 614.1(9) and were untimely.On Defendants' motion for summary judgment, the district court held that Plaintiff's causes of action arose out of patient care and were barred by section 614.1(9), the two-year statute of limitations governing malpractice action. The Supreme Court affirmed, holding that each of Plaintiff's allegations originated from representations regarding patient care and the patient care Defendants provided, and therefore, Plaintiff's claims were untimely under section 614.1(9). View "Kostoglanis v. Yates" on Justia Law

The Supreme Court affirmed the ruling of the district court granting summary judgment in favor of a finance company in this contract dispute, holding that the contract was properly ratified despite any allegation of forgery.Natalya Rodionova Medical Care (NRMC) allegedly entered into a financing agreement with GreatAmerica Financial Services Corporation for the leasing of telephone and copier products. Pursuant to the agreement, NRMC made monthly payments totaling seven months worth of installments but then attempted to cancel the finance agreement. When NRMC discontinued further payments GreatAmerica sued for breach of contract and unjust enrichment. In its answer NRMC alleged that the finance agreement appeared to be signed by NRMC's sole shareholder but that the signature was a forgery. The district court granted summary judgment for GreatAmerica, reasoning that NRMC ratified the contract through its conduct regardless of who signed the contract. The Supreme Court affirmed, holding that NRMC's failure to reject goods over a seven-month period and its payment of periodic invoices amounted to a ratification. View "GreatAmerica Financial Services Corp. v. Natalya Rodionova Medical Care, P.C." on Justia Law

The Supreme Court answered a certified question under Nev. R. App. P. 5 concerning an insurer's right to reimbursement, holding that when a party to a contract performs a challenged obligation under protest and a court subsequently determines that the contract did not require performance, the party may generally recover in restitution, thus giving effect to the terms of the parties' bargain.Insurer filed this declaratory judgment action seeking reimbursement of expenses it had occurred in defending Insured against a suit by a third party. The district court concluded that Insurer was not entitled to reimbursement. The Ninth Circuit Court of Appeals affirmed, concluding that the suit did not trigger a duty to defend. The Supreme Court accepted a certified question from the Ninth Circuit regarding the issue. The Supreme Court then held (1) no contract governed the right to reimbursement in this case; and (2) under the principle of unjust enrichment, a party that performs a disputed obligation under protest and does not in fact have a duty to perform is entitled to reimbursement. View "Nautilus Insurance Co. v. Access Medical, LLC" 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

Hall filed various contract, statutory, and common-law claims against Old Republic in federal district court for failing to indemnify Hall under its title insurance policies. The district court concluded that, although the unpaid Penta pre-policy-date work is a defect under Covered Risk 2 and an encumbrance under Covered Risk 10, coverage is precluded by Exclusions 3(a) and 3(d), which bar claims for liens and work performed after the policy date. The district court found that Hall had not raised a genuine dispute of material fact that Penta's liens were for unpaid work before the policy date, and granted Old Republic's motion for summary judgment and denied Hall's motion for partial summary judgment.The Fifth Circuit concluded that the insuring clauses do not cover Hall's Penta lien losses. The court explained that any doubt about whether Covered Risks 2 and 10 could possibly be read to cover the Penta lien losses at issue here is removed by the fact that the parties also signed standard ALTA Form 32-06. In so doing, the parties specifically contracted to eliminate one coverage provision of the standard-form insurance policy—Covered Risk 11(a). Even assuming arguendo that the 32-06 endorsements and the Covered Risks conflict or result in an ambiguity about whether the Penta lien losses are covered, the court explained that it is the more general provisions that suggest that there may be coverage (under Hall's theory), while the more specific provisions instruct that there is no such coverage. Under basic principles of contract interpretation, the specific controls the general. Therefore, the court need not review the district court's conclusions regarding Exclusions 3(a) and 3(d) to affirm the judgment.The court also affirmed the district court's grant of Old Republic's motion for summary judgment on Hall's bad-faith and Texas Insurance Code claims. The court explained that, because Hall is not entitled to indemnification for the Penta lien losses, Hall cannot show that Old Republic acted in bad faith in denying its claim. Furthermore, because Hall alleges no other harm apart from the Penta lien losses, Hall cannot demonstrate that Old Republic caused it any harm in violating the Texas Insurance Code—assuming arguendo that the Texas Insurance Code applies, and that Old Republic ran afoul of its provisions. Finally, the court affirmed the district court's grant of Old Republic's motion for summary judgment on Hall's independent-counsel (or duty-to-defend) claim. View "Hall CA-NV, LLC v. Old Republic National Title Insurance Co." on Justia Law

The School terminated Pack's employment as a teacher after less than a year and published a press release about Pack on its website, allegedly criticizing Pack, which remains available on the School’s website. Pack sued the School. The Elkhart Truth ran an article later that month under the headline: “Fired Northridge teacher, an atheist, sues Middlebury Community Schools for religious discrimination.” Pack and the School settled that case. The School agreed to maintain a level of confidentiality and agreed to tell Pack’s prospective employers only limited information about him. The parties agreed that neither would disparage the other party. The settlement agreement did not mention the 2014 press release. Pack sued Elkhart Truth in state court, alleging defamation. School Superintendent Allen gave an affidavit supporting Truth’s motion to dismiss. Pack later recruited two acquaintances to call the School and pose as prospective employers. During one call, Allen said that Pack’s termination was “a matter of public record.” During another, Allen said Pack was terminated “for cause.”Pack sued for breach of the settlement agreement. The Seventh Circuit affirmed summary judgment for the School on all claims. The School had no contractual obligation to remove the pre-existing press release from its website, enjoys absolute privilege for the affidavit submitted in the Truth litigation, and did not disclose contractually forbidden information to “prospective employers” because the callers were not “prospective employers.” View "Pack v. Middlebury Community Schools" on Justia Law

Plaintiffs filed suit alleging that pressure tactics used by Quicken Loans and TSI to influence home appraisers to raise appraisal values to obtain higher loan values on their homes constituted a breach of contract and unconscionable inducement under the West Virginia Consumer Credit and Protection Act. The district court granted summary judgment to plaintiffs.The Fourth Circuit concluded that class certification is appropriate and that plaintiffs are entitled to summary judgment on their claims for conspiracy and unconscionable inducement. However, the court concluded that the district court erred in its analysis of the breach-of-contract claim. The court explained that the district court will need to address defendants' contention that there were no damages suffered by those class members whose appraisals would have been the same whether or not the appraisers were aware of the borrowers' estimates of value—which one might expect, for example, if a borrower's estimate of value was accurate. The court agreed with plaintiffs that the covenant of good faith and fair dealing applies to the parties' contract, but concluded that it cannot by itself sustain the district court's decision at this stage. The district court may consider the implied covenant of good faith and fair dealing to the extent that it is relevant for evaluating Quicken Loans' performance of the contracts. Accordingly, the court affirmed in part and vacated and remanded in part. View "Alig v. Quicken Loans Inc." on Justia Law

At issue in this appeal was a civil action to collect a debt under a contract that contained an arbitration provision. The defendants appealed the master in equity's order refusing to set aside the entry of their default. The court of appeals dismissed the appeal on the basis that an order refusing to set aside an entry of default was not immediately appealable. The defendants filed a petition for a writ of certiorari claiming the order was immediately appealable because it had the effect of precluding their motion to compel arbitration, and in fact, the order states, "Defendants' motion to stay and compel arbitration is denied as [the defendants are] in default." Finding no reversible error, the South Carolina Supreme Court affirmed the court of appeals. View "Palmetto Construction Group, LLC v. Restoration Specialists, LLC" on Justia Law