Justia Contracts Opinion Summaries

The trial court did not err in dismissing Plaintiffs’ action for lack of subject matter jurisdiction due to Plaintiffs’ failure to exhaust administrative remedies in seeking damages for denied Medicaid reimbursement claims.The court of appeals reversed the trial court’s order, ruling that the trial court erred in dismissing Plaintiffs’ complaint without resolving certain factual issues and that Plaintiffs sufficiently demonstrated that it would be futile to pursue administrative remedies. The Supreme Court reversed, holding that the court of appeals erred in reversing the dismissal of Plaintiffs’ claims where Plaintiffs failed to exhaust their administrative remedies prior to filing suit and failed to demonstrate futility of the available remedies at this time. View "Abrons Family Practice & Urgent Care, PA v. North Carolina Department of Human Services" on Justia Law

John Hoehn ("John") and his wife, Margaret, jointly owned the Foley Flea Market in Foley, Alabama ("the property"). In 2009, John, Margaret, and Roman Fitzpatrick (John and Margaret’s daughter) entered into an agreement to sell John's "1/2 undivided interest in the property" to Fitzpatrick and her then-husband, Paul Kihano. The agreement specified that Margaret would "retain her 1/2 undivided interest in the property." The agreement stated that Fitzpatrick and Kihano "shall be entitled to enter into possession of [the] property so long as [they are] not in default in the performance of [the agreement]." The agreement also made clear that title to John's "1/2 undivided interest in the property" would not pass to Fitzpatrick and Kihano until all the payments had been made under the agreement. John executed a quitclaim deed conveying his one-half interest in the property to Margaret; the quitclaim deed made no mention of the agreement. In 2013, Margaret changed the locks on the property so that Fitzpatrick could no longer access the property or operate the flea market. Fitzpatrick quit making payments under the agreement in December 2013. Fitzpatrick, with her sisters, initiated this lawsuit against Margaret, Kihano, and Mixon alleging intentional interference with a contract and intentional interference with business relations; against John's estate, breach of contract; and against Margaret, Kihano, and Mixon, tortious interference with an inheritance. In case no. 1160393 (Margaret's cross-appeal of the circuit court's judgment in favor of Fitzpatrick on Fitzpatrick's claims of interference with a contract and intentional interference with business relations), the Alabama Supreme Court reversed judgment in favor of Fitzpatrick and rendered judgment in favor of Margaret. In case no. 1160348 (Fitzpatrick's appeal of the amount of Fitzpatrick's compensatory-damages award and the circuit court's judgment in favor of Margaret on Margaret's counterclaim against Fitzpatrick), the Supreme Court dismissed the appeal as moot insofar as Fitzpatrick challenged the compensatory-damages award and affirmed the judgment on Margaret's counterclaim. View "Fitzpatrick v. Hoehn" on Justia Law

The Supreme Court affirmed the district court’s denial of a motion to compel arbitration, although for different reasons than those of the district court.In denying the motion to compel arbitration, the district court concluded that the agreement to arbitrate concerned or related to an insurance policy and was thus unenforceable under Neb. Rev. Stat. 25-2602.01(f)(4). On appeal, Appellant argued that the district court erred in denying the motion to compel arbitration and in determining that arbitration agreement concerned or related to an insurance policy. The Supreme Court affirmed, holding that there was a failure of proof regarding the arbitration itself because the record did not show that the relevant parties agreed to submit future disputes to binding arbitration. View "Zweiback Family L.P. v. Lincoln Benefit Life Co." on Justia Law

The Supreme Court affirmed the district court’s denial of a motion to compel arbitration, although for different reasons than those of the district court.In denying the motion to compel arbitration, the district court concluded that the agreement to arbitrate concerned or related to an insurance policy and was thus unenforceable under Neb. Rev. Stat. 25-2602.01(f)(4). On appeal, Appellant argued that the district court erred in denying the motion to compel arbitration and in determining that arbitration agreement concerned or related to an insurance policy. The Supreme Court affirmed, holding that there was a failure of proof regarding the arbitration itself because the record did not show that the relevant parties agreed to submit future disputes to binding arbitration. View "Zweiback Family L.P. v. Lincoln Benefit Life Co." on Justia Law

The Court of Appeal reversed the judgment of dismissal entered after the trial court sustained without leave to amend the demurrer of Trader Joe's to plaintiff's first amended complaint. The court held that plaintiff adequately stated a cause of action for intentional interference with contractual relations. The court reasoned that one, like Trader Joe's here, who was not a party to the contract or an agent of a party to the contract was a "stranger" for purpose of the tort of intentional interference with contract, and plaintiff need not allege an independently wrongful act to state his cause of action for interference with contract. The court held that plaintiff adequately stated causes of action for intentional and negligent interference with prospective economic advantage. View "Redfearn v. Trader Joe's Company" on Justia Law

The Court of Appeal reversed the judgment of dismissal entered after the trial court sustained without leave to amend the demurrer of Trader Joe's to plaintiff's first amended complaint. The court held that plaintiff adequately stated a cause of action for intentional interference with contractual relations. The court reasoned that one, like Trader Joe's here, who was not a party to the contract or an agent of a party to the contract was a "stranger" for purpose of the tort of intentional interference with contract, and plaintiff need not allege an independently wrongful act to state his cause of action for interference with contract. The court held that plaintiff adequately stated causes of action for intentional and negligent interference with prospective economic advantage. View "Redfearn v. Trader Joe's Company" on Justia Law

After paying a total of $15,493.00 on his $5,000 loan, MacDonald filed a putative class action concerning the loan agreement. He cited RICO and New Jersey state usury and consumer laws, arguing that the agreement is usurious and unconscionable for containing a provision requiring that all disputes be resolved through arbitration conducted by a representative of the Cheyenne River Sioux Tribe (CRST) and a clause that delegates questions about the arbitration provision’s enforceability to the arbitrator. No CRST arbitral forum exists. The agreement also purported to waive all of the borrower’s state and federal statutory rights. The district court denied a motion to compel arbitration. The Third Circuit affirmed, concluding that the agreement directs arbitration to an illusory forum without a provision for an alternative forum, and the forum selection clause is not severable, so that the entire agreement to arbitrate, including the delegation clause, is unenforceable. View "MacDonald v. Cashcall Inc." on Justia Law

After paying a total of $15,493.00 on his $5,000 loan, MacDonald filed a putative class action concerning the loan agreement. He cited RICO and New Jersey state usury and consumer laws, arguing that the agreement is usurious and unconscionable for containing a provision requiring that all disputes be resolved through arbitration conducted by a representative of the Cheyenne River Sioux Tribe (CRST) and a clause that delegates questions about the arbitration provision’s enforceability to the arbitrator. No CRST arbitral forum exists. The agreement also purported to waive all of the borrower’s state and federal statutory rights. The district court denied a motion to compel arbitration. The Third Circuit affirmed, concluding that the agreement directs arbitration to an illusory forum without a provision for an alternative forum, and the forum selection clause is not severable, so that the entire agreement to arbitrate, including the delegation clause, is unenforceable. View "MacDonald v. Cashcall Inc." on Justia Law

The Williams Parties brought suit against Fannie Mae and Wells Fargo, asserting claims against defendants for breach of contract premised on a violation of the notice terms in a Deed of Trust, violations of the Texas Property Code, and wrongful foreclosure. On appeal, the Williams Parties appealed the dismissal of their breach of contract claims against Fannie Mae and the grant of summary judgment in favor of Wells Fargo. The court held that the district court did not err in holding that Wells Fargo was not liable for breach of the Deed of Trust where the competent summary judgment evidence reflected that Wells Fargo was never a party to or an assignee of the Deed of Trust. Therefore, Wells Fargo had no liability and summary judgment for Wells Fargo was appropriate. The district court did not abuse its discretion by granting a motion for reconsideration and, on the merits, Fannie Mae's agreement in the deed of trust to give notice of foreclosure was independent of the Williams Parties' agreement under the note to pay monthly installments to satisfy the debt. Therefore, the court affirmed as to Wells Fargo, reversed as to the claim that Fannie Mae breached the deed of trust by failing to give notice, and remanded the claim against Fannie Mae for further proceedings. View "Williams v. Wells Fargo Bank, N.A." on Justia Law

The Williams Parties brought suit against Fannie Mae and Wells Fargo, asserting claims against defendants for breach of contract premised on a violation of the notice terms in a Deed of Trust, violations of the Texas Property Code, and wrongful foreclosure. On appeal, the Williams Parties appealed the dismissal of their breach of contract claims against Fannie Mae and the grant of summary judgment in favor of Wells Fargo. The court held that the district court did not err in holding that Wells Fargo was not liable for breach of the Deed of Trust where the competent summary judgment evidence reflected that Wells Fargo was never a party to or an assignee of the Deed of Trust. Therefore, Wells Fargo had no liability and summary judgment for Wells Fargo was appropriate. The district court did not abuse its discretion by granting a motion for reconsideration and, on the merits, Fannie Mae's agreement in the deed of trust to give notice of foreclosure was independent of the Williams Parties' agreement under the note to pay monthly installments to satisfy the debt. Therefore, the court affirmed as to Wells Fargo, reversed as to the claim that Fannie Mae breached the deed of trust by failing to give notice, and remanded the claim against Fannie Mae for further proceedings. View "Williams v. Wells Fargo Bank, N.A." on Justia Law