Justia Contracts Opinion Summaries

Annalia Montany, a student in the University of New England’s (UNE) occupational therapy master’s degree program, injured her back when Scott McNeil, an instructor playing the role of a mock patient, feigned a fall while Montany attempted to assist him in transferring from a wheelchair into a bed. Because of her back problem she failed a practical exam and did not receive a passing grade for the course. Montany was subsequently dismissed from the program. Montany filed suit against UNE and McNeil, alleging negligence and breach of contract. The district court entered summary judgment in favor of Defendant. The First Circuit affirmed, holding (1) contrary to Montany’s assertion, expert testimony was required in this case; and (2) Montany’s breach of contract claims failed. View "Montany v. University of New England" on Justia Law

This lawsuit arose from a dispute over an alleged commercial lease agreement between Plaintiffs, owners of certain property, and Defendants, who Plaintiffs claimed breached the terms of the lease. The superior court granted summary judgment in favor of Defendants, finding no genuine issues of material fact. The Supreme Court vacated the judgment of the superior court, holding that genuine issues of material fact existed in connection with two factual issues, and because of the fact-intensive nature of both of these inquiries, the case was not suitable for summary judgment and should, instead, have been resolved after a trial on the merits. View "Albert J. Branch Revocable Trust v. Interstate Battery Center" on Justia Law

In this dispute concerning the rights and obligations of Appellants pursuant to a pipeline capacity agreement they had with Appellee, the Supreme Judicial Court affirmed the judgment of the business and consumer docket denying Appellants’ application to vacate several arbitration awards pursuant to Me. Rev. Stat. 14, 5938(1)(C). The court held that, contrary to Appellants’ argument on appeal, the arbitrator did not exceed his authority pursuant to the statute because the arbitration awards did not directly contradict the language of the agreement or constitute a manifest disregard for the terms of the agreement. View "XPress Natural Gas, LLC v. Woodland Pulp, LLC" on Justia Law

A jury awarded Plaintiff future lost profits based on Defendants’ failure to comply with their covenants not to compete and covenants not to solicit. The jury also awarded Plaintiff exemplary damages and attorney fees. The trial court awarded Plaintiff the full amount of damages. The court of appeals reversed and rendered a take-nothing judgment in part and remanded in part, concluding, inter alia, that the evidence was legally insufficient to support the jury’s award of future lost profits and that the exemplary damages award was unconstitutionally excessive. The Supreme Court affirmed in part and reversed in part, holding (1) the court of appeals did not err in concluding that the evidence of future lost profits was legally insufficient; (2) the court of appeals’ remitted exemplary damages award was unconstitutionally excessive; and (3) the court of appeals properly found that remand of the issue of attorney’s fees was proper. The court remanded the case to the court of appeals so that it may reconsider its suggested remittitur of exemplary damages. View "Horizon Health Corp. v. Acadia Healthcare Co." on Justia Law

This consolidated action began as four separate lawsuits arising from transactions involving a dairy operation. This appeal focused on the claims asserted by Jack McCall against Max Silva personally. Max Silva appeals from the judgment of the district court in Twin Falls County finding him personally liable for the purchase of 116 dairy cows. After a bench trial, the district court found Silva personally liable for the purchase of the cows and dismissed the other claims against him. Silva contended that the district court erred when it found him personally liable for the purchase. Silva also argued that the district court abused its discretion when it failed to award him attorney fees proportionate to the claims on which he prevailed at trial. Finding no reversible error, the Idaho Supreme Court affirmed. View "McCall v. Silva" on Justia Law

Plaintiff Fat Bullies Farm, LLC (Fat Bullies), and the counterclaim defendants, Donald Gould and Peter Simmons, appealed certain superior court findings and rulings made during the course of litigation with defendants Alan and Donna Perkins and Lori and Bret Devenport, involving the sale of a 3.1 acre horse farm in North Hampton known as Runnymede Farm. When the Devenports purchased the property in 1998, they promised to operate it as a horse farm in perpetuity, and to allow the former owner to maintain an office on site. Simmons told the Devenports that he was interested in purchasing the property. The Devenports told Simmons they would only sell if the buyer agreed to the horse farm and on site office conditions. Simmons spoke with Gould about purchasing the property jointly with the intent to develop and/or resell it. The two created Fat Bullies “for the purpose of acquiring real estate for development or resale.” After amendments to the purchase contract, the Devenports reiterated that they would sell the property only if Fat Bullies committed to operating it as a horse farm. Despite their intentions to develop the property, Simmons and Gould agreed. The parties executed a sales agreement. No payment had been made on the property; word got back to Lori Devenport that Simmons had talked to others in North Hampton about purchasing the farm. The Devenports rescinded the agreement, believing Simmons lied to them about promising to operate Runnymede as a horse farm. Fat Bullies invoked an option, but the Devenports refused to sell. In 2011, the Devenports sold Runnymede to the Perkinses. After trial, the jury returned a verdict in favor of the Devenports on Fat Bullies’ breach of contract claim, finding that Fat Bullies failed to prove the existence of a contract by a preponderance of the evidence, and a verdict in favor of Fat Bullies, Simmons, and Gould on the Devenports’ fraudulent inducement claim. The New Hampshire Supreme Court reversed the trial court with respect to a Consumer Protection Act violation decision; the Court reversed with respect to attorney fees related to that Act decision. The Court affirmed in all other respects, and remanded for further proceedings. View "Fat Bullies Farm, LLC v. Devenport" on Justia Law

Plaintiff filed suit against Scottsdale for coverage under a Business and Management Indemnity Policy. The Eighth Circuit affirmed the district court's grant of summary judgment to Scottsdale, holding that Food Market presented no evidence providing notice over seven months was "as soon as practicable." Where, as here, notice is a condition precedent to coverage, a showing of prejudice was not required. Finally, the district court properly found the policy unambiguous; Scottsdale expressly relied on the notice provision when denying coverage; and there was no waiver. View "Food Market Merchandising v. Scottsdale Indemnity" on Justia Law

A jury found for Plaintiff on her claim for breach of contract and on her promissory-estoppel claim. The jury rendered verdicts against Defendants on their counterclaims. Defendants filed a motion for judgment notwithstanding the verdict (JNOV) or for a new trial. The trial court granted the motion, concluding that the jury verdicts were improper and inconsistent and that they should be set aside in favor of granting a new trial. The circuit court denied Plaintiff’s motion to reconsider. Plaintiff appealed. The Supreme Court dismissed the appeal for lack of appellate jurisdiction because Defendants’ motion for JNOV or a new trial was filed prior to the entry of the judgment. Therefore, the circuit court’s order granting a new trial was a nullity, and the posttrial motion was deemed denied thirty days after its filing date. Because neither party filed a notice of appeal after the judgment was entered the court had no timely or effective notice of appeal from the disposition of the posttrial motion. View "Worsham v. Day" on Justia Law

Upon their divorce, Wife and Husband entered into a marital dissolution agreement (MDA) that contained a provision entitling the prevailing party to an award of appellate attorney’s fees in subsequent legal proceedings. The MDA was incorporated into the parties’ final divorce decree. Wife later filed a relocation motion seeking to modify the parties’ parenting plan. Wife then filed a motion for judgment against Husband for reimbursement of uncovered medical expenses. After a hearing, the trial court granted both motions filed by Wife and awarded Wife attorney’s fees based on the MDA. The court of appeals affirmed but declined Wife’s request for an award of fees and costs on appeal. Wife appealed, arguing that she was entitled to appellate attorney’s fees. The Supreme Court reversed, holding that Wife was entitled to an award of appellate attorney’s fees incurred before the court of appeals under the parties’ MDA. View "Eberbach v. Eberbach" on Justia Law

Ridgeway was employed as a Stryker sales representative from 2001-2013. Stryker’s faxed employment offer stated Ridgeway’s employment was contingent on his signing and returning an offer letter, a form non-compete agreement, and a code of conduct. From 2000-2005, Stryker used the same form non-compete agreement with all employees, which included a one-year non-compete clause, a customer non-solicit clause, an employee non-solicit clause, and a Michigan choice-of-law clause and a Michigan forum-selection clause. Ridgeway signed and returned the documents. Despite becoming one of Stryker’s top performers, in 2013, Ridgeway considered working for Stryker’s competitor, Biomet. Ridgeway claims that Stryker indicated that he was not covered under a non-compete agreement. Stryker terminated his employment and Ridgeway began working for Biomet within his former Stryker Louisiana-based sales territories. Stryker filed suit. The district court denied Ridgeway’s motion to dismiss based on the forum-selection clause in the non-compete agreement. Biomet terminated Ridgeway for fear of liability. A jury returned a verdict in favor of Stryker on its breach-of-contract, breach-of-fiduciary-duty, and misappropriation-of-trade-secrets claims and awarded damages in the amount of $745,195. The Sixth Circuit affirmed, rejecting Ridgeway’s challenges to the authenticity of the agreement and to the choice of law provision. View "Stone Surgical LLC v. Stryker Corp." on Justia Law