Justia Contracts Opinion Summaries

K&A Enterprises of Mississippi, LLC, filed suit against Phyllis and James Maness for breach of contract. The claim arose from Phyllis and James Maness’s termination of the Option Contract between the parties. K&A Enterprises of Mississippi, LLC, alleged that Phyllis and James Maness failed to provide clear title, and in response, Phyllis and James Maness filed a Counterclaim for Declaratory Judgment. K&A Enterprises of Mississippi, LLC, filed a Partial Motion for Summary Judgment on Liability, a Partial Motion for Summary Judgment on Damages, and a Motion to Dismiss the Counterclaim, or in the alternative, for Summary Judgment. The trial court granted all three motions, denied the subsequent motions for reconsideration, and the Manesses appealed. Finding no reversible error, the Mississippi Supreme Court affirmed. View "Maness v. K & A Enterprises of Mississippi, LLC" on Justia Law

Arizona equitable indemnity law does not incorporate the Restatement (First) of Restitution section 78 because it conflicts with Arizona’s general equitable indemnity principles.Michael Bovre rented a vehicle from Payless Car Rental System Inc. Payless offered Bovre supplemental liability insurance (SLI) under a policy provided by KnightBrook Insurance Co. Bovre caused an accident while driving the rental vehicle that injured Lorraine and Robert McGill. The McGills sued Bovre. The parties settled. Bovre assigned to the McGills his claims against KnightBrook and Payless for their alleged failure to provide supplemental liability insurance (SLI) and agreed to an adverse judgment. Thereafter, the McGills sued Payless and KnightBrook seeking to recover the judgment. The McGills and KnightBrook entered into a settlement in which the McGills’ claims against Payless were assigned to KnightBrook, which paid the McGills the $970,000 SLI policy limit. KnightBrook then filed an action in federal court against Payless, asserting an equitable indemnification claim for the $970,000 it paid McGills. Relying on the First Restatement section 78, the district court ruled that KnightBrook was entitled to equitable indemnification from Payless for the $970,000 SLI policy limits. On appeal, the Ninth Circuit certified two questions to the Supreme Court. The court answered the first question as set forth above, which rendered moot the second question. View "KnightBrook Insurance Co. v. Payless Car Rental System Inc." on Justia Law

McKie Ford Lincoln, Inc. filed suit against Scott Hanna, its former sales manager, and Gateway Automotive, LLC, the automobile dealership Hanna owned, seeking to enforce a non-competition and disclosure agreement that Hanna signed when he was hired by McKie Ford. Hanna and Gateway filed a counterclaim against McKie Ford alleging a cause of action for barratry. The parties filed cross-motions for summary judgment. The circuit court granted the summary judgment motion filed by Hanna and Gateway and denied McKie Ford’s motion. The Supreme Court affirmed the denial of McKie Ford’s motion for summary judgment, holding that Hanna was no longer subject to the non-compete agreement when he commenced ownership and operation of Gateway, and therefore, Hanna was entitled to judgment as a matter of law. View "McKie Ford Lincoln, Inc. v. Hanna" on Justia Law

Givens, a Missouri resident, suffered from renal failure, was on dialysis for about 10 years and had experienced multiple strokes. In 2009, she suffered an additional injury from gadolinium dye, a substance used in MRIs, joined a class action related to the dye, and received about $255,000 in settlement proceeds. Givens signed an agreement allowing the National Foundation for Special Needs Integrity to manage a trust for her benefit while she lived. Givens named herself as the only beneficiary. Givens died a month after funding the trust, leaving more than $234,000. Givens failed to specify a remainder beneficiary. The Foundation claimed that the agreement entitled it to retain any remaining trust assets. Givens’s Estate claimed that it is entitled to the money for the benefit of Givens’s children, arguing that the agreement is ambiguous and should be construed against the Foundation, or that the court should use its equitable power. The district court rejected the Estate’s arguments. The Seventh Circuit reversed, finding the agreement ambiguous on the key question. The overwhelming weight of evidence shows that Givens intended that any remaining assets pass to her children rather than to the Foundation. The court did not address equitable theories or a laches defense. View "National Foundation For Special Needs Integrity, Inc. v. Reese" on Justia Law

Contrary to the holding of the district court, Appellant filed a timely legal-malpractice claim under Minn. Stat. 541.05(1)(5).Respondent, Appellant’s attorney, prepared an antenuptial agreement for Appellant and his then-fiancee, Cynthia Gatliff, but the agreement did not include statutorily required witness signatures, making it unenforceable. One year after Appellant married Gatliff, Respondent drafted a will for Appellant that incorporated the antenuptial agreement by reference. When Gatliff later filed for divorce, she alleged that the antenuptial agreement was invalid due to its lack of witness signatures. Appellant subsequently sued Respondent for legal malpractice. While the invalid execution of the antenuptial agreement fell outside the six-year limitations period for malpractice claims, Appellant argued that subsequent representations by Respondent that the anteuptial agreement was valid were separate legal-malpractice claims that each triggered their own statute of limitations periods. The district court granted Respondent’s motion for judgment on the pleadings, and the court of appeals affirmed. The Supreme Court reversed, holding that Appellant sufficiently alleged that Respondent’s will drafting formed the basis for a separate malpractice claims within the limitations period. View "Frederick v. Wallerich" on Justia Law

MACOM’s predecessor developed semiconductors using gallium nitride (GaN), obtained patents related to that technology, and sold those patents to Infineon's predecessor, retaining rights under separate license agreement. That agreement defines a “Field of Use” characterized by GaN-on-silicon technology and licenses MACOM to practice the GaN patents within the “Field of Use only.” MACOM and Infineon share rights to practice the patents in the Field of Use. The agreement defines an “Exclusive Field” within the Field of Use in which MACOM has exclusive rights to practice the patents—even as against Infineon. Infineon notified MACOM that it believed MACOM had breached the agreement by making and selling products using GaN-on-silicon-carbide technology, which is distinct from GaN-on-Si technology and outside the Field of Use. MACOM responded that the GaN-on-SiC sales were minimal and that any breach had been cured. Infineon terminated the Agreement. MACOM sued, asserting contract claims and seeking a declaratory judgment of noninfringement and obtained a preliminary injunction. The Federal Circuit affirmed in part, agreeing that MACOM could likely establish that its activity outside the Field of Use did not breach the agreement and that MACOM would suffer irreparable harm in the absence of a preliminary injunction. The court vacated two sentences in the injunction for lacking specificity. View "MACOM Technology Solutions Holdings, Inc. v. Infineon Technologies Americas Corp." on Justia Law

Renasant Bank purchased a Financial Institution Bond (the Bond), which covers losses caused by employees only when certain criteria are met. A Mississippi statute, Miss. Code Ann. 81-5-15, requires bank employees to post fidelity bonds that protect against "acts of dishonesty." The Fifth Circuit held that, assuming arguendo that the Bond was governed by section 81-5-15, the Bond's terms were enforceable as written because they were consistent with the statute. The court agreed with the district court that the Bank failed to produce evidence necessary to support its breach-of-contract claim and thus was entitled to summary judgment. View "Renasant Bank v. St. Paul Mercury Insurance Co." on Justia Law

In this action challenging an insurance company’s doubling of Plaintiff’s insurance premium, the Seventh Circuit reversed the district court’s dismissal of Plaintiff’s complaint for failure to state a claim, holding that Plaintiff was entitled to relief on her contract claim and that the allegations Plaintiff raised were enough to permit her to go forward on her other theories.When Plaintiff was sixty-seven years old, she discovered that Metropolitan Life Insurance Company (MetLife) more than doubled her insurance premium. Plaintiff brought this lawsuit against MetLife on behalf of herself and a proposed class, alleging breach of contract, deceptive and unfair business practices, and common-law fraud. The district court granted MetLife’s motion to dismiss for failure to state a claim, concluding that the insurance policy unambiguously permitted MetLife to raise Plaintiff’s premium. The First Circuit disagreed, holding that the allegations raised in the complaint were enough to entitle Plaintiff to prevail on the liability phase of her contract claim and to go forward on her remaining claims. View "Newman v. Metropolitan Life Insurance Co." on Justia Law

Plaintiff Stacy Gaasch, as personal representative for the Estate of Troy Gaasch, filed suit against St. Paul File and Marine Insurance Company, alleging the insurance company failed to timely provide reasonable and necessary medical treatment as ordered by the Workers' Compensation Court. Troy required multiple surgeries over several years due to his work-related injury. Troy was hospitalized due to his work-related injury. He allegedly became malnourished with accompanying weight loss and different physicians recommended a nutritional consult. A nurse case manager recommended monthly a nutritional consult. Troy died during his hospitalization approximately six months after the initial recommendation for a nutritional consult. Prior to his work-related injury, Troy underwent a gastric bypass surgery and allegedly suffered from a malabsorption syndrome secondary to this surgery. A disagreement arose between insurer and Troy concerning whether the insurer was required to pay for a nutritional consult. Insurer claimed Troy's nutritional problems were created prior to his work-related injury and his nutritional state in the hospital was not due to the work-related injury. The company moved for summary judgment which was granted. Plaintiff appealed. The Oklahoma Supreme Court held: (1) Plaintiff's district court action alleging breach of contract also included a request for damages resulting from the death of the workers' compensation claimant; (2) the district court action was based upon alleged delay by a workers' compensation insurer in providing medical care as previously awarded by the Worker's Compensation Court; and (3) the district court action against the workers' compensation insurer was precluded by an exclusive remedy provided by the Workers' Compensation Act. “Plaintiff attempts to go around this procedure we classified as a ‘jurisdictional requirement’ . . .by characterizing the claim as a breach of contract and an action for damages resulting from an alleged wrongful death. The clear public policy expressed in the amended version of Art. 23 sec. 7 requires available workers' compensation remedies for any type of wrongful death claim to be pursued in the Workers' Compensation Court when required by the workers' compensation statutes.” View "Gaasch v. St. Paul Fire & Marine Ins. Co." on Justia Law

Oklahoma and the Citizen Potawatomi Nation (the “Nation”) entered into a Tribal-State gaming compact; Part 12 of which contained a dispute-resolution procedure that called for arbitration of disagreements “arising under” the Compact’s provisions. The terms of the Compact indicated either party could, “[n]otwithstanding any provision of law,” “bring an action against the other in a federal district court for the de novo review of any arbitration award.” In Hall Street Associates, LLC. v. Mattel, Inc., 552 U.S. 576, (2008), the Supreme Court held that the Federal Arbitration Act (“FAA”) precluded parties to an arbitration agreement from contracting for de novo review of the legal determinations in an arbitration award. At issue before the Tenth Circuit Court of Appeals was how to treat the Compact’s de novo review provision given the Supreme Court’s decision in Hall Street Associates. The Nation argued the appropriate course was to excise from the Compact the de novo review provision, leaving intact the parties’ binding obligation to engage in arbitration, subject only to limited judicial review under 9 U.S.C. sections 9 and 10. Oklahoma argued the de novo review provision was integral to the parties’ agreement to arbitrate disputes arising under the Compact and, therefore, the Tenth Circuit should sever the entire arbitration provision from the Compact. The Tenth Circuit found the language of the Compact demonstrated that the de novo review provision was a material aspect of the parties’ agreement to arbitrate disputes arising thereunder. Because Hall Street Associates clearly indicated the Compact’s de novo review provision was legally invalid, and because the obligation to arbitrate was contingent on the availability of de novo review, the Tenth Circuit concluded the obligation to arbitrate set out in Compact Part 12 was unenforceable. Thus, the matter was remanded to the district court to enter an order vacating the arbitration award. View "Citizen Potawatomi Nation v. State of Oklahoma" on Justia Law