Justia Contracts Opinion Summaries

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of the Dunn’s Corners Fire District on its complaint seeking a declaration that it was not obligated to provide fire protection services to certain property located in the Village of Bradford in the town of Westerly, Rhode Island.Dunn’s Corners was a party to a contract that required Westerly Ambulance Corps, also a defendant in this case, to dispatch Dunn’s Corners to sites and locations situated within the Bradford Fire District. The hearing justice granted Dunn’s Corners’ motion for summary judgment, finding that the subject property lay outside of the Bradford Fire District. The Supreme Court affirmed, holding (1) Appellant’s argument that a declaratory judgment should not have issued because the Bradford Fire District was not a party to the action lacked merit; and (2) because Appellant conceded at oral argument that the subject property was not currently situated within any fire district, Appellant’s second argument that there remained a genuine issue of material fact as to whether the property was located within the Bradford Fire District was without merit. View "Dunn’s Corners Fire District v. Westerly Ambulance Corps" on Justia Law

Defendants A&M Structuring, LLC, and Edward Couture, individually and as manager of A&M Structuring appealed a judgment entered in favor of Lynn Flaten and from a post-judgment order denying their motions to amend the judgments and "regarding ownership or interest in levied property." Flaten sued for claims of breach of contract, unjust enrichment, and fraud. Flaten alleged he agreed to sell certain real property located in Williams County to defendants for $275,000 in February 2012, defendants paid $50,000 as a down payment, but failed to pay the remaining amounts due for the property. Flaten also alleged the defendants agreed to sell him certain real property located in McKenzie County, consisting of three individual lots. Flaten alleged defendants never delivered the property. After review of the trial court record, the North Dakota Supreme Court concluded the district court did not err in granting partial summary judgment or abuse its discretion in denying the post-judgment motions. View "Flaten v. Couture" on Justia Law

Defendants A&M Structuring, LLC, and Edward Couture, individually and as manager of A&M Structuring appealed a judgment entered in favor of Lynn Flaten and from a post-judgment order denying their motions to amend the judgments and "regarding ownership or interest in levied property." Flaten sued for claims of breach of contract, unjust enrichment, and fraud. Flaten alleged he agreed to sell certain real property located in Williams County to defendants for $275,000 in February 2012, defendants paid $50,000 as a down payment, but failed to pay the remaining amounts due for the property. Flaten also alleged the defendants agreed to sell him certain real property located in McKenzie County, consisting of three individual lots. Flaten alleged defendants never delivered the property. After review of the trial court record, the North Dakota Supreme Court concluded the district court did not err in granting partial summary judgment or abuse its discretion in denying the post-judgment motions. View "Flaten v. Couture" on Justia Law

The Fifth Circuit affirmed the district court's dismissal of Delek's challenge to an arbitrator's award in an action alleging that the company violated a collective bargaining agreement (CBA), which required that employees get first crack at new work unless certain exceptions apply. The court held that the arbitrator's exercise of his discretion did not conflict with the CBA, and that the district court did not abuse its discretion in finding that Delek's challenge was without justification and subject to a fee award. View "Delek Refining, Limited v. Local 202" on Justia Law

The nature of the function a municipality was performing when it entered into a contract governs the analysis of whether the municipality was engaged in its governmental or proprietary function and thus whether the municipality was immune from suit.Plaintiff filed this suit alleging that the City of Jacksonville breached its lease agreements with Plaintiff. The City filed a motion for summary judgment arguing that governmental immunity barred the breach of contract claim. The trial court granted the motion. The court of appeals affirmed based on governmental immunity, concluding that the governmental/proprietary dichotomy that applies to tort claims does not apply to breach of contract claims. The Supreme Court reversed, holding that the dichotomy applies whether a municipality commits a tort or breaches a contract. On remand, the court of appeals held that governmental immunity applied to bar Plaintiff’s contract claim because the claim arose from the City’s performance of a governmental function. The Supreme Court reversed, holding that the contract claim arose from the City’s performance of a proprietary function so governmental immunity did not apply. View "Wasson Interests, Ltd. v. City of Jacksonville" on Justia Law

The one-satisfaction rule applied to this case, and therefore, the trial court erred in denying the nonsettling defendant settlement credits.At issue on this appeal was Plaintiff’s claims against nonsettling defendants alleging breach of contract, fraud, and other causes of action. Plaintiff had earlier settled with four other defendants. The jury returned a verdict in favor of Plaintiff. The nonsettling defendants asserted that, under the one-satisfaction rule, they were entitled to offset the final judgment by the amounts the four settling defendants paid to Plaintiff, plus interest. The trial court disagreed and rendered judgment against the nonsettling defendants, jointly and severally, for the full jury award. The court of appeals affirmed the trial court’s denial of settlement credits, ruling that Plaintiff’s claims against the nonsettling defendants were independent of the other injuries Plaintiff alleged against the settling defendants. The Supreme Court reversed, holding that the nonsettling defendants were entitled to reduce the judgment by the total amount of the settlements Plaintiff received and any applicable interest. View "Sky View At Las Palmas, LLC v. Mendez" on Justia Law

In this dispute over an offset provision in an oil and gas lease the Supreme Court reversed the judgment of the court of appeals reversing the trial court’s summary judgment in the lessee’s favor on the grounds that the lessee did not conclusively demonstrate compliance with the provision.On appeal, the court of appeals determined that the lessee did not conclusively prove that it complied with the offset provision and thus was not entitled to summary judgment. In reversing, the Supreme Court held (1) the offset provision contained specific requirements, and the lessee met those requirements; and (2) the court of appeals read a requirement into the lease that its unambiguous language did not support. View "Murphy Exploration & Production Co. v. Adams" on Justia Law

Buyer contracted in 2004 to purchase Sellers’ Francisco gas station, to build a condominium project. Buyer had to obtain the necessary “Entitlements” for development. It took eight years to secure the conditional use permit. Sellers alleged the deal had expired. In 2014, Buyer sued, asserting breach of contract (specific performance) and quantum meruit to recover costs for work performed at Sellers’ Mountain View gas station. On the breach of contract claim, the court found the jury deadlocked and declared a mistrial. At Buyer’s request, the court decided that claim and found Buyer failed to perform his contractual obligations and was not entitled to specific performance. On the quantum meruit claim, the jury awarded Buyer $156,000 as the reasonable cost of work at Seller’s Mountain View property. The court vacated that verdict because Buyer had not produced a certificate of licensure to show compliance with Business and Professions Code 7031. The court of appeal affirmed in part. Buyer’s election to have the court decide his specific performance claim waived any claims of error he had and there was substantial evidence that Buyer failed to perform by not timely paying the purchase price after securing the Entitlements; he was properly denied specific performance. The court reversed on the quantum meruit claim. Public policy is not served by vacating the verdict awarded Buyer, an undisputed California-licensed contractor, for work he performed. View "Tierney v. Javaid" on Justia Law

The Court of Appeal affirmed the trial court's judgment in favor of a good faith purchaser at a lien sale that had acquired the contents of a storage unit free and clear of plaintiff's claim that the sale violated the California Self-Service Storage Facility Act. The court held that the conversion action was barred by the good faith purchaser provisions of Bus. & Prof. Code section 21711. The court also held that the action was barred by the doctrine of judicial estoppel which precluded a party from relying upon a theory in a legal proceeding inconsistent with one previously asserted. In the first suit against the storage facility owner, plaintiff claimed the owner did not abide by the requirements of the Act. In this case, plaintiff claimed that the Act did not apply and that defendant was liable for conversion regardless of whether he was a good faith purchaser. View "Nist v. Hall" on Justia Law

The circuit court did not err in denying Sellers’ motions for judgment as a matter of law and for a new trial in this case brought by Buyers against Sellers of a house alleging violation of statutory disclosure requirements.Shortly after purchasing a house, Buyers experienced water-penetration issues. Buyers sued Sellers, claiming violation of the statutory disclosure requirements, fraudulent misrepresentation, fraudulent concealment, and negligent misrepresentation. The jury found in favor of Buyers on its statutory disclosures claim and in favor of Sellers on the remaining claims. On appeal, the Supreme Court held that the circuit court (1) did not err in denying Sellers’ renewed motion for judgment of a matter of law and Sellers’ motion for new trial; and (2) did not abuse its discretion in declining to award attorney fees. View "Center of Life Church v. Nelson" on Justia Law