Justia Contracts Opinion Summaries

The Supreme Court vacated in part and affirmed in part the Supreme Court’s grant of summary judgment in favor of Defendants - the Town of Scituate and others - on Plaintiff’s claims alleging breach of a memorandum of understanding (MOU).Specifically, Plaintiff alleged promissory estoppel and breach of contract, breach of confidentiality, tortious interference with a contract, and fraudulent misrepresentation. The trial justice granted summary judgment for Defendants, finding, among other things, that the MOU was not a binding agreement. The Supreme Court vacated the portion of the judgment granting summary judgment on Plaintiff’s breach of contract claim and otherwise affirmed, holding that the facts presented established that a contract was formed. View "Coccoli v. Town of Scituate Town Council" on Justia Law

In this insurance dispute, the Supreme Court held that the issue of whether the trial court properly disregarded some of the jury’s findings should be remanded to the court of appeals for reconsideration in light of this Court’s decision in USAA Texas Lloyds Co. v. Menchaca, __ S.W.3d __ (Tex. 2018).Plaintiffs sued their insurer, State Farm, for breach of contract and Insurance Code violations. The jury found that both parties breached the insurance contract but that Plaintiffs breached first. The jury then awarded damages for State Farm’s breach of the policy and for Plaintiffs’ extra-contractual claims. The trial court disregarded two of the jury’s findings about Plaintiffs’ breach of the insurance contract and rendered judgment for Plaintiffs. The court of appeals affirmed. While State Farm's appeal was pending, the Supreme Court issued its final opinion and judgment in Menchaca, which clarified whether an insured can recover policy benefits based on an insurer’s violation of the Texas Insurance Code even though the jury failed to find that the insurer failed to comply with its obligations under the policy. On appeal, the Supreme Court held (1) State Farm’s first issue should be remanded for reconsideration in light of Menchaca; and (2) as to the remaining issues, the court of appeals’ judgment is affirmed. View "State Farm Lloyds v. Fuentes" on Justia Law

The Supreme Court affirmed the district court’s order granting Heather Hope Schumacher’s motion to enforce a settlement agreement she entered into with Cowboy’s LLC after Cowboy’s failed to pay Schumacher the money as agreed.Schumacher claimed that her divorce decree awarded her certain property, that her ex-husband failed to convey the property to her, and that she had filed lien statements against the disputed property, which was then owned by Cowboy’s. The parties eventually reached a settlement agreement requiring Cowboy’s to pay Schumacher $98,742 in return for her release of all liens against the property. When Cowboy’s failed to pay Schumacher as agreed, Schumacher sought an order requiring Cowboy’s to comply with the settlement agreement. The district court ordered Cowboy’s to perform as agreed. The Supreme Court affirmed, holding (1) Schumacher’s liens were valid and enforceable; and (2) the “deemed denial” of Cowboy’s motion to set aside the order enforcing the settlement agreement was properly denied. View "Cowboy's LLC v. Schumacher" on Justia Law

The Fifth Circuit affirmed the district court's grant of summary judgment for an insurer, in an action seeking a declaratory judgment that the insurer owed no coverage under a commercial property insurance policy. The insured then counterclaimed for declaratory judgment, breach of the insurance contract, and violations of the Texas Insurance Code. The court held that the insured failed to meet its burden to offer evidence that would allow a trier of fact to segregate covered losses from non-covered losses. Therefore, because the insured failed to meet its burden to show what portion, if any, of the claimed damage occurred during the coverage period, the insurer was entitled to summary judgment on its claim seeking declaratory judgment. The insured's counterclaims failed for the same reason. View "Certain Underwriters at Lloyd's of London v. Lowen Valley View, LLC" on Justia Law

The Supreme Court affirmed the the judgment of the circuit court setting aside the jury’s verdict awarding CGI Federal Inc. $12 million in damages for its fraudulent inducement and breach of contract claims against FCi Federal, Inc., holding that the circuit court did not commit reversible error in its judgment.This lawsuit related to a teaming agreement entered between the parties to obtain a federal government contract. After the jury rendered its verdict, the circuit court set it aside on the grounds that the teaming agreement did not obligate FCi to extend a subcontract to CGI and that CGI did not prove fraud damages. The court further granted FCi’s motion for summary judgment on CGI’s alternative claim for unjust enrichment. The Supreme Court affirmed, holding that the circuit court did not err in (1) overturning the jury’s verdict on the breach of contract claim; (2) vacating the jury’s award of damages for the fraudulent inducement claim because CGI cannot recover any lost profits on this claim; and (3) entering summary judgment for FCi on the unjust enrichment claim because CGI may not recover on a quasi-contractual claim that is otherwise precluded by a contract which CGI has affirmed. View "CGI Federal Inc. v. FCi Federal, Inc." on Justia Law

A party may implicitly waive an antiwaiver clause in a contract through conduct, but there must be clear intent to waive both the underlying contract provision and the antiwaiver clause.Defendant hired Plaintiff to provide snow removal services. The parties’ contract required Plaintiff to maintain a certain amount of insurance coverage. The contract included an antiwaiver clause stating that Defendant’s failure to notice a deficiency in Plaintiff’s insurance coverage could not be construed as a waiver of the insurance provision. When Defendant discovered that Plaintiff had failed to purchase the required insurance, Defendant terminated the contract. Plaintiff brought this action asserting that Defendant had waived its right to terminate the contract because Defendant effectively waived the insurance requirement by making payments to Plaintiff despite its noncompliance. The jury found Defendant liable for breach of contract. The Supreme Court reversed, holding (1) Plaintiff produced no evidence of waiver beyond Defendant’s failure to insist on performance of the insurance requirements; and (2) Defendant was within its rights to terminate the contract. View "Mounteer Enterprises, Inc. v. Homeowners Association for Colony at White Pine Canyon" on Justia Law

At issue was the proper method for calculating the quantum meruit value of an attorney’s services when a client terminates the contingent-fee agreement before a matter concludes.Respondent retained Appellant-law firm under a contingent-fee agreement to assist with asbestos litigation. Two months before settling a claim upon which Appellant had worked for about ten years, Respondent discharged Appellant. The district court dismissed Appellant’s attempt to recover a portion of the settlement funds, concluding that Appellant failed to prove the value of the services that it had provided. The court of appeals reversed, holding that the district court applied the incorrect test for determining quantum meruit. The Supreme Court affirmed as modified, holding (1) district courts should use eight factors to determine the quantum meruit value of a discharged contingent-fee attorney’s services; and (2) a remand was necessary so that the district court may consider the contingent-fee argument between the parties, in addition to the other relevant factors identified herein. View "Faricy Law Firm, P.A. v. API, Inc. Asbestos Settlement Trust" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the district court concluding that a grain-handling contract between the parties in this case that was to “continue indefinitely” was perpetual in duration, not indefinite, and therefore not terminable at will.Chippewa Valley Ethanol Company, LLLP (CVEC) sought to end its contract with Glacial Plains Cooperative on the ground that it was a contract of indefinite duration, terminable at will be either party. The district court ruled in favor of Glacial Plains, finding that CVEC had wrongfully terminated the grain-handling contract. The court of appeals affirmed, ruling that the intent of the parties should prevail over the general rule that contract without definite duration are terminable at will upon reasonable notice. The Supreme Court reversed and remanded for further proceedings, holding (1) the parties’ contract was one of indefinite duration and was therefore terminable at will by either party upon reasonable notice after a reasonable time as passed; and (2) it is for the district court to weigh the evidence and apply the law to determine whether a reasonable time has passed such that the contract may be terminated at will with reasonable notice. View "Glacial Plains Cooperative v. Chippewa Valley Ethanol Co." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for CyberPower in an action alleging breach of contract, fraud, and unpaid wages. Plaintiff alleged that CyberPower breached a Compensation Agreement that secured his employment until the company reached a specific monetary sales threshold. The court held that there was no ambiguity on the question of whether CyberPower clearly intended to modify plaintiff's at-will status with the Compensation Agreement where the text of the agreement indicated that it governed only compensation. The court rejected plaintiff's remaining arguments. View "Ayala v. CyberPower Systems (USA), Inc." on Justia Law

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