Justia Contracts Opinion Summaries

The Supreme Court affirmed in part and reversed and remanded in part the judgment of the appellate court reversing the judgment of the trial court granted Defendants’ special motions to strike the second through sixth causes of action advanced by Plaintiffs in Plaintiffs’ dispute with the City of Carson and other defendants, holding that some of Plaintiffs’ causes of action were based on protected activities under Cal. Code Civ. Proc. 425.26(e)(2) and (e)(4) but others were not.After Plaintiffs brought this lawsuit Defendants responded by making a motion under the anti-SLAPP statute. The Supreme Court held that the causes of action asserted in Plaintiffs’ dispute with Defendants did not arise from Defendants’ acts in furtherance of their right of free speech in connection with a public issue with the exception of two discrete claims, which were within the scope of subdivision (e)(2) and (e)(4) of the anti-SLAPP statute, thus affirming in part and reversing in part the appellate court’s judgment. View "Rand Resources, LLC v. City of Carson" on Justia Law

The Second Circuit affirmed the district court's judgment in an action against Direct Energy, alleging breach of contract, deceptive and unfair trade practices, and unjust enrichment. Plaintiff had entered into a consumer electricity contract with Direct Energy which initially guaranteed a fixed electricity rate. Consistent with the terms of the contract, the fixed‐rate plan was converted into a variable rate plan after the first twelve months.The court affirmed the district court's grant of summary judgment in favor of Direct Energy and held that, by the contract's plain terms, Direct Energy promised that the variable rate would be set in its discretion and that it would reflect "business and market conditions," a phrase which encompasses more than just procurement costs. Because plaintiff's claims under the Connecticut Unfair Trade Practices Act were entirely duplicative of his contract claim, they also failed. Finally, the court affirmed the district court's dismissal of plaintiff's unjust enrichment and Massachusetts unfair trade practices claims. View "Richards v. Direct Energy Servs., LLC" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court that Plaintiff’s implied warranty claim was actionable only under the Deceptive Trade Practices-Consumer Protection Act (DTPA), Tex. Bus. & Com. Code 17.41-17.63, holding that the claim for breach of implied warranty of good and workmanlike repairs in this case was not brought under the DTPA and thus was not covered by the DTPA’s two-year limitations period.Plaintiff sought damages for injuries to himself and his small plane when the plane’s engine failed and it crash-landed. Defendant moved to strike Plaintiff’s petition, arguing that the DTPA’s two-year statute of limitations applied. The trial court agreed with Defendant and struck the petition. The court of appeals affirmed. The Supreme Court reversed, holding that Plaintiff’s breach of implied warranty claim was not barred by the DTPA limitations period. View "Nghiem v. Sajib" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals that the evidence was legally sufficient to support the trial court’s award of both actual and punitive damages as to all Plaintiffs in this lawsuit, holding that Plaintiffs were entitled to actual damages but were not entitled to punitive damages.Plaintiffs brought suit against Bombardier Aerospace Corporation for breach of contract, breach of express warranty, and fraud. The jury found in favor of Plaintiffs, and the trial court awarded both actual and punitive damages. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the evidence was legally sufficient to support the award of actual damages to Plaintiffs; but (2) the limitation-of-liability clauses in the parties’ agreements barred the punitive damages award under the circumstances. View "Bombardier Aerospace Corp. v. SPEP Aircraft Holdings LLC" on Justia Law

The Supreme Court affirmed the trial court’s denial of Sabre Travel International, Ltd.’s motion to dismiss Deutsche Lufthansa Airline Group’s tortious interference with contract claim based on preemption, holding that the federal Airline Deregulation Act (ADA) did not preempt an airline’s claim for tortious interference with contract brought under state law.The trial court denied Sabre’s motion to dismiss but certified a legal question under Tex. Civ. Prac. & Rem. Code 51.014(d) providing for permissive interlocutory appeals. The court of appeals denied the permissive interlocutory appeal without explanation. After Sabre filed a petition for review in the Supreme Court, Lufthansa argued that the Court had no jurisdiction to hear the case because the court of appeals denied the permissive appeal. The Supreme Court held (1) under Tex. Gov. Code 22.225(d), an appellate court’s denial of a permissive interlocutory appeal does not prevent the Supreme Court from reviewing the merits of the interlocutory order; and (2) there was no preemption under the ADA. View "Sabre Travel International, Ltd. v. Deutsche Lufthansa AG" on Justia Law

The First Circuit reversed the district court’s dismissal of claims against Schechtl Maschinenbau GmbH, a German company, holding that, contrary to the conclusion of the district court, the exercise of personal jurisdiction over Schechtl comported with due process.Stephen Knox’s hand was injured at his work when he operated a machine manufactured by Schechtl. The machine had been sold to Knox’s employer by MetalForming, Inc., an American company located in Georgia and Schechtl’s U.S. distributor. Knox sued both Schechtl and MetalForming in Massachusetts state court. MetalForming removed the case to Massachusetts federal district court and filed crossclaims against Schechtl. The district court granted Schechtl’s motion to dismiss, concluding that Schechtl had not purposefully availed itself of the privilege of doing business in Massachusetts. The First Circuit reversed, holding that Knox and MetalForming met their burden of demonstrating that Schechtl purposefully availed itself of the privilege of conduct activities within Massachusetts. View "MetalForming, Inc. v. Schechtl Maschinenbau GmbH" on Justia Law

Appellants Ryan and Kathryn McFarland owned real property in Garden Valley, Idaho, which feathred three structures insured through Liberty Mutual Insurance Group: a main cabin; a detached garage with an upstairs “bonus room”; and a pump house containing a geothermal well. The policy provided two types of coverage for structures. Coverage A (“Dwelling Coverage”) provided up to $188,500 in coverage for “the dwelling on the ‘residence premises’. . . including structures attached to the dwelling . . .” and Coverage B (“Other Structures Coverage”) provided up to $22,350 for “other structures on the ‘residence premises’ set apart from the dwelling by clear space.” In February 2017, a radiant heater burst in the bonus room and damaged the garage and its contents. After the McFarlands filed a claim, Liberty stated that the damage was covered under the policy. Believing the damage to fall under the Dwelling Coverage, the McFarlands hired contractors to repair the damage. However, after Liberty paid out a total of $23,467.50 in March 2017, Liberty stated that the coverage was exhausted because the damage fell under the Other Structures Coverage. This led the McFarlands to sue, alleging among other claims, breach of contract based on Liberty’s interpretation of the policy. The parties filed cross motions for summary judgment on the issue of whether the damage fell under the Dwelling Coverage or the Other Structures Coverage. Ruling that the policy unambiguously provided coverage for the garage under the Other Structures Coverage, the district court denied the McFarlands’ motion and granted Liberty’s. The McFarlands appealed. Finding that the policy at issue here failed to define the term "dwelling", and the term was reasonably subject to differing interpretations, the Idaho Supreme Court reversed the award of summary judgment and remanded for further proceedings. View "McFarland v. Liberty Insurance Corp" on Justia Law

Until recently, Sexing Tech held a monopoly on the market for sexed cattle semen in the United States. Sperm‐sorting technology separates bull semen into X‐chromosome bearing and Y‐chromosome bearing sperm cells; the resulting “sexed semen” is used to inseminate cows artificially so that dairy farmers can breed only milk‐producing cows. ABS, a bull‐stud operation, sued, alleging that Sexing Tech had unlawfully monopolized the domestic sexed‐semen market in violation of section 2 of the Sherman Act by using its market power to impose coercive contract terms. ABS sought a declaratory judgment proclaiming those contracts invalid, to permit its own entry into that market. Sexing Tech counterclaimed that ABS infringed its patents and breached the contract by misappropriating trade secrets in developing ABS’s competing technology. Three claims went to trial: ABS’s antitrust claim and Sexing Tech’s patent infringement and breach of contract counterclaims. The Seventh Circuit affirmed the district court, holding that ABS violated a confidentiality agreement it had with Sexing Tech and that Sexing Tech’s patent was not invalid on obviousness grounds. The jury’s assessments of two of the three patent claims still at issue cannot be reconciled under the rules governing dependent claims and enablement, and so a new trial is necessary on them. View "ABS Global, Inc. v. Inguran, LLC" on Justia Law

In this appeal involving a dispute over payment for the construction of a traditional timber frame home, the Supreme Judicial Court affirmed the judgment of the superior court calculating the damages recoverable under the Unfair Trade Practice Act (UTPA) stemming from Contractor’s violation of the Home Construction Contracts Act (HCCA), holding that, the superior court did not err in its judgment.Contractor brought this action seeking to be paid for his unpaid labor. The superior court concluded (1) Contractor was entitled to the money he had already received from Homeowners under the theory of quantum meruit; (2) Homeowners did not meet their burden of proof as to their counterclaims; and (3) Contractor violated the HCCA by failing to furnish a written contract, which was prima facie evidence of a UTPA violation. The Supreme Judicial Court affirmed, holding (1) while the parties did not sign a contract in this case, the superior court’s application of quantum meruit was appropriate; (2) the superior court did not err in concluding that Homeowners failed to prove their counterclaims; (3) Homeowners were not entitled to additional damages under the UTPA; and (4) the attorneys fees award in this case was sufficient. View "Sweet v. Breivogel" on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court affirming the judgment of the district court in favor of Appellee, Appellant’s landlord, holding that Appellant’s violation of his lease in three ways that were independent from his possession of marijuana justified Appellee’s termination of the lease.Appellee issued Appellant a notice that it was terminating the parties’ lease, stating that Appellant’s use and possession of marijuana, as well as some of Appellant’s other activities, violated the terms of the parties’ lease. Appellee then filed an forcible entry and detainer complaint, and the district court entered judgment granting possession of the apartment to Appellant. Appellant appealed, arguing that because he had a certificate to use marijuana for medical purposes, Appellee and the district court were required to reasonably accommodate his possession and use of marijuana. The Supreme Judicial Court affirmed, holding that Appellant’s violations of his lease that were independent from his possession of marijuana, standing alone, justified Appellee’s termination of the lease. View "Sherwood Associates LP v. Jackson" on Justia Law