Justia Contracts Opinion Summaries

The Supreme Court affirmed the district court’s order awarding attorney fees and costs to Defendant on its counterclaim after the court determined Defendant to be the “prevailing party” following bifurcated trials, in which the parties settled as to damages on Plaintiff’s claims in an amount that exceeded Defendant’s damages judgment on its counterclaim.Specifically, the Court held that the district court did not abuse its discretion by failing to aggregate the settlement recovery and damages award in this case because (1) there is no Nevada statute or court rule that requires the trial court to offset a damages judgment on one party’s counterclaim by the amount recovered by another party in settling its claim to determine which side is the prevailing party; and (2) the most reasonable interpretation of Nev. Rev. Stat. 18.010(2)(a) and 18.020(3) precludes the use of settlement recovery for this purpose. View "Northern Nevada Homes, LLC v. GL Construction, Inc." on Justia Law

In this dispute over a noncompete agreement (NCA) the Supreme Court reaffirmed its previous holdings that an NCA must be limited to the geographical areas in which an employer has particular business interests and emphasized that this precedent remains applicable in instances where the NCA imposes a nationwide restriction on the former employee. The Court further clarified that an employer seeking a preliminary injunction enforcing an NCA bears the burden of making a prima facie showing of the NCA’s reasonableness.In this dispute over an NCA, the Supreme Court reversed the district court’s grant of the motion for a preliminary injunction filed by Respondent, an employer, seeking to enforce the terms of a noncompete agreement (NCA) against Appellant, a former employee, holding that Respondent failed to make a prima facie showing that the NCA was reasonable by showing its restrictions did not extend beyond date geographical areas in which Respondent conducted business. View "Shores v. Global Experience Specialists, Inc." on Justia Law

The First Circuit vacated the district court’s grant of Liberty Mutual Insurance Company’s summary judgment motion in this case alleging that Liberty breached Plaintiff’s contractual rights by wrongfully denying his request for coverage under an insurance policy, holding that the district court’s reasoning in granting Liberty’s motion for summary judgment was flawed.Plaintiff argued in his complaint that Liberty improperly denied his coverage request under the Directors and Officers insurance policy that Liberty had issued to a Puerto Rico hospital where Plaintiff served as the medical director. The district court concluded that, under the policy, the “Claim” that would give rise to the “Loss” for which Plaintiff sought coverage should be “deemed first made” before the policy took effect and, therefore, was not covered by the policy. The First Circuit vacated the district court’s order granting Liberty’s summary judgment motion, holding that the “Claim” for which Plaintiff sought coverage from Liberty was not “first made” prior to the beginning of the policy at issue, and the district court wrongly construed the policy in concluding otherwise. View "Jimenez-Castaner v. Liberty Mutual Insurance Co." on Justia Law

A Himalaya Clause that protects downstream carriers from suit by a cargo owner does not, in and of itself, limit the cargo owner's ability to receive the recovery to which it is entitled. After Royal SMIT's transformers were damaged during shipment from the Netherlands to Louisiana, Royal SMIT and its insurers filed suit against the carriers with whom the intermediary had contracted. The Fifth Circuit affirmed the district court's grant of summary judgment for the carriers, holding that the through bill of lading’s Himalaya Clause protected downstream carriers from being sued by Royal. The court rejected Royal's claims that there was a material issue of fact as to whether the parties agreed to be bound by the Himalaya Clause and held that Royal failed to articulate a basis for overriding the clear terms of the through bill of lading. View "Royal SMIT Transformers BV v. Onego Shipping & Chartering, BV" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to American Family in an action alleging breach of contract, negligent misrepresentation, and violation of Minnesota's consumer fraud statutes. The court held that American Family did not breach the contract because nothing in the policy imposed on American Family a contractual obligation to make objectively reasonable or accurate replacement cost estimates; American Family did not negligently misrepresent the replacement cost of plaintiffs home where, regardless of any breach of duty, no genuine dispute existed as to justifiable reliance upon the estimates; and plaintiffs could point to any promise, misrepresentation, or false statement made by American Family, let alone one that they relied upon, justifiably or unjustifiably, in deciding to purchase or renew the policy. View "Nelson v. American Family Mutual Insurance Co." on Justia Law

The Supreme Court affirmed the order of the district court denying Vincent Toenjes’ (Vince) motion to modify his maintenance obligation to Joni Hardy (Joni), his former wife, and requiring him to pay Joni’s attorney fees and granted Joni attorney fees on appeal, holding that there was no error in the district court’s judgment.The district court concluded that, even where Vince had lost his job, the terms of the parties’ settlement agreement relating to maintenance had not become unconscionable under the facts of this case. The Supreme Court agreed, holding that the district court (1) correctly interpreted the maintenance provisions of the parties’ marital and property settlement agreement; (2) did not abuse its discretion in determining that the changed circumstances did not make the agreement unconscionable; and (3) properly granted attorney fees to Joni based on the terms of the settlement agreement. Further, Joni was entitled to attorney fees on appeal under the same provision of the settlement agreement. View "In re Marriage of Toenjes" on Justia Law

The Eighth Circuit reversed the district court's dismissal of a breach-of-contract action to recover unpaid insurance premiums. The court held that the administrative procedures available to the insurer were too informal to require exhaustion under then-applicable Missouri law. Therefore, Travelers had no obligation to exhaust its administrative remedies before filing its lawsuit. The court remanded for further proceedings. View "Travelers Property Casualty Insurance Company of America v. Jet Midwest Technik" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of an action against WireCo's workers' compensation insurance carriers, Liberty, seeking damages for excess premiums that WireCo allegedly paid on three of Liberty's insurance policies. The court held that the plain language and established purpose of the Missouri vexatious refusal to pay statute indicated that it applied to claims filed under a policy that related to a covered loss and that a breach of a contract of overcharging or of failure to refund premium was not a loss contemplated by the statute. Therefore, a loss under the statute did not include excess premium payments.The court also held that only the theories of breach of contract were before the district court at summary judgment; even assuming the rating plans were incorporated into the policies, and that Liberty breached the contracts, WireCo must present evidence that Liberty's alleged breaches caused WireCo to suffer damages; and Liberty was entitled to summary judgment on WireCo's breach of contract claims because WireCo failed to present evidence that it would have paid lower premiums if Liberty had complied with the notice and documentation requirements of the Missouri and Texas schedule rating plans. View "WireCo WorldGroup, Inc. v. Liberty Mutual Fire Insurance Co." on Justia Law

Appellant Jennifer Eastman sought a declaratory judgment that she was entitled to underinsured motorist insurance coverage (“UIM coverage”) under her auto insurance policy (the “Policy”) with Respondent Farmers Insurance Company (“Farmers”). Eastman was involved in a motor vehicle accident while traveling in a van operated by the Spokane Transit Authority (“STA”). Eastman sustained injuries as a result of the accident. Both the at-fault driver and STA held insurance policies. Eastman collected $50,000 from the at-fault driver’s insurance policy. Additionally, Eastman collected $48,846 in UIM coverage from STA’s insurance policy. Eastman’s special damages from the accident exceeded the amount that she collected from the two insurance policies. Eastman thereafter filed a claim with her insurer, Farmers, in an attempt to collect her own UIM coverage under the Policy. Specifically, Eastman sought her UIM coverage limit ($500,000) minus the $98,846 that she had already collected from the other insurance policies. Farmers denied Eastman’s claim based on an exclusion within the Policy which eliminated UIM coverage in situations where the insured was riding in another vehicle that had UIM coverage. The district court granted summary judgment in favor of Farmers, ruling that an exclusion contained in the Policy precluded UIM coverage for Eastman’s injuries. Finding that the clause in Eastman's policy violated Idaho's public policy, the Idaho Supreme Court vacated the district court's judgment and remanded this case with direction to invalidate the insurance exclusion at issue here. View "Eastman v. Farmers Insurance" on Justia Law

This appeal involved an Idaho district court’s denial of a jury trial under Rule 39(b) of the Idaho Rules of Civil Procedure and the decision to pierce the corporate veil. The dispute stemmed from a transaction between Kym Nelson, who acted on behalf of KDN Management Inc., (“KDN”), and WinCo, Foods, LLC (“WinCo”), for concrete floor work that KDN performed in several WinCo stores. The district court found that KDN had overcharged WinCo for the work, and awarded WinCo $2,929,383.31 in damages, including attorney fees. The district court also held Nelson and two entities associated with her, SealSource International, LLC, and KD3 Flooring LLC, jointly and severally liable for WinCo’s damages. Nelson, SealSource and KD3 argued on appeal to the Idaho Supreme Court that the trial court erred in concluding: (1) Nelson was personally liable for damages relating to this dispute; and (2) that KDN, SealSource and KD3 were alter egos of one another. Nelson and the corporate co-defendants also argued the district court abused its discretion by denying their motion for a jury trial under Rule of Civil Procedure 39(b). Finding no reversible error in the district court’s judgment, the Idaho Supreme Court affirmed the judgment and award of attorney fees to WinCo. View "KDN Management, Inc. v. WinCo" on Justia Law