Justia Contracts Opinion Summaries

The issue this case presented for the Supreme Court's review arose from a deficiency action brought by appellant SunTrust Bank (“SunTrust”) as the assignee under a motor vehicle conditional sales contract following its repossession and sale of a motor vehicle purchased by appellee Mattie Venable. Specifically, the issue was which statute of limitations applied here: the four-year statute of limitation set forth in OCGA 11-2-725 (1) applicable to actions on contracts for the sale of goods, or the six-year statute of limitation found in OCGA 9-3-24, generally applicable to actions on simple written contracts. After review, the Court concluded that this action was subject to the four-year statute of limitation found in 11-2-725 (1). View "SunTrust Bank v. Venable" on Justia Law

Plaintiff entered an original song and music video to a variety of companies affiliated with Sony Music Entertainment (Sony) as part of a songwriting contest sponsored by Sony. Plaintiff later sued Sony alleging contract and intellectual property claims. The district court entered an order compelling arbitration and dismissed Plaintiff’s case with prejudice, concluding that the claims were subject to mandatory arbitration under the Federal Arbitration Act and that Plaintiff failed to make a cognizable claim under Fed. R. Civ. P. 12(b)(6). Plaintiff appealed, arguing that the district court erred in ruling that he failed to allege sufficient facts to support his claims. The First Circuit affirmed, holding that because the district court’s rulings that Plaintiff’s claims were subject to mandatory arbitration provided an independent basis for dismissing his claims, the Court did not need to address Plaintiff’s challenge to the district court’s decision to dismiss his complaint on factual sufficiency grounds. View "Cortes-Ramos v. Sony Corp. of America" on Justia Law

In 1963, USPS and Bellevue’s predecessor-in-interest entered into a twenty-year initial lease with five options to renew the lease and an option to purchase certain property. When USPS attempted to exercise the purchase option, Bellevue refused to honor it. The district court granted summary judgment for USPS and ordered specific performance of the sale of the property. The court applied Washington’s heightened evidentiary standard for specific performance and held that USPS has shown clearly and unequivocally that it has a contractual right to purchase the property. Even under Washington law’s high standard for awarding specific performance, USPS successfully provided “clear and unequivocal evidence” that it exercised its options to extend the term of the lease in strict compliance with the terms of the lease, and that the lease therefore continued to exist through the time it also properly exercised its purchase option. Finally, the court agreed with the district court that the 1963 lease remained valid. Accordingly, the court affirmed the district court’s order granting summary judgment to USPS and compelling specific performance for the sale of the property. View "USPS v. Bellevue Post Office" on Justia Law

Stafford and Woodruff Smith (Woody) were brothers. Their father established Smith Chevrolet, and over the years the brothers have co-owned several auto dealerships, other businesses, and parcels of real property. The brothers each owned 50% of Staffwood, an entity that owned properties and other assets. In 2010, a dispute arose between the brothers involving their business dealings, and in 2010, the brothers entered into a settlement agreement (the 2010 Agreement) that gave ownership of Smith Chevrolet to Stafford. The 2010 Agreement also identified four parcels of land that either brother could purchase through a bid process. Between 2010 and 2012, various transactions occurred between Smith Chevrolet, Woody, Stafford, and Staffwood which culminated in another dispute between the brothers and another settlement agreement (the 2012 Agreement). The 2012 Agreement provided that each brother had the right to initiate a bid process to purchase the properties owned by Staffwood. In 2013, Woody sent a letter to the management of Staffwood in which he asserted that he had won the bidding process and asked Stafford to clear the title to the Smith Chevrolet Property. Woody appealed the district court’s grant of judgment on the pleadings and award of attorney fees to Stafford in his subsequent suit seeking specific performance of his winning bid. Finding no reversible error in the district court's judgment, the Supreme Court affirmed. View "Smith v. Smith" on Justia Law

In 2011, Medical Recovery Services, LLC (“the Collection Agency”), filed this action against defendants Allison and Nathan Olsen to recover on two entities’ unpaid medical bills. In 2012, the parties stipulated that the Collection Agency could recover a judgment against defendants and that it would forbear executing on the judgment if the defendants paid $100 per month between the 25th and 30th of each month until the judgment was paid. The court entered a judgment providing that the Collection Agency could recover from the Defendants the sum of $4,973.46. Defendants failed to make any payment on the judgment, and the Collection Agency attempted to execute on the judgment. The Collection Agency sought to execute on defendants’ bank account, but the account had been closed. The Collection Agency then sought a continuing garnishment to obtain Mr. Olsen’s disposable earnings from Petersen, Moss, Hall & Olsen, but that garnishment was returned unsatisfied because “Defendant is a partner in the firm, not an employee.” The Collection Agency also sought to execute on Mr. Olsen’s partnership interest, but the writ was returned unsatisfied because Mr. Olsen’s equity in the partnership was stated to be zero. The Collection Agency then sought to depose Stephen Hall, the partner in the law firm who had signed the responses to the writs of garnishment. The Collection Agency agreed to forgo taking his deposition if Hall would make $250 bi-monthly payments until the judgment was paid in full. Hall made those payments, but the Collection Agency would not accept final payment endorsed "payment in full" because it wanted to seek post-judgment attorney fees. Defendants filed a motion seeking to compel the Collection Agency to record a satisfaction of judgment in every county in which it had recorded the original judgment. The Agency responded by filing for an award of post-judgment fees it incurred trying to collect on its judgment. The Agency's motion was denied, and the Agency estopped from further collection of fees, citing the agreement reached in satisfying the judgment. The district court upheld the magistrate court's judgment. Finding that Hall only agreed to satisfy the judgment, the Supreme Court concluded the district court erred in affirming the magistrate. The case was remanded for further proceedings. View "Medical Recovery Svcs. v. Olsen" on Justia Law

This case centered around sixteen shares in the Malletts Bay Club, Inc. (MBC) that were sitting in escrow since 1998, when George Gordon conveyed the associated real property to J. Douglas Johnson. On summary judgment, the trial court ruled that defendant James McGarry, as transfer agent for the shares, breached the parties’ contract and his fiduciary duty by failing to issue the shares to Gordon’s successors upon their demand, and that defendant MBC had waived its right to challenge Gordon’s failure to transfer those shares to Johnson by agreeing to the Gordon-to-Johnson conveyance. After its review of this matter, the Vermont Supreme Court concluded that the agreement defining the parties’ rights and obligations with respect to the MBC shares did not require McGarry to return the shares to Gordon on demand, and that based on undisputed evidence, MBC did not waive its right to enforce its bylaws with respect to the transaction. Defendants were therefore entitled to summary judgment and plaintiffs were not. The Court remanded for further proceedings to resolve any remaining claims of plaintiffs that were not the subject of the cross motions for summary judgment. View "Rounds v. Mallets Bay Club, Inc." on Justia Law

Appellants purchased tickets to Super Bowl XLV and were either displaced from their seats, relocated, or had an obstructed view of the field. The majority of the affected ticketholders settled with the NFL. However, appellants in this instance elected to file suit, alleging various claims relating to breach of contract and fraud. Most of appellants’ claims were dismissed before trial, and class certification was denied. Seven individual appellants went to trial against the NFL and prevailed on breach of contract, but not on fraudulent inducement claims. The court concluded that, because appellants have presented no authority supporting that a third-party vendor with limited responsibility is also responsible for the performance of the express ticket terms, appellants’ argument that the Cowboys are liable for their tort claims fails; an inference of fraudulent inducement is untenable; and the economic loss rule bars appellants' claims. The court also concluded that the contract claims failed where the unambiguous term of the contract entitling ticketholders to “a spectator seat for the game” was not breached by an obstructed view of the video board. Furthermore, the fraudulent inducement claims failed because appellants were not fraudulently induced to buy Super Bowl tickets thinking they would see the game on the video board. As to class certification, the court concluded that the district court did not abuse its discretion in refusing to certify the Displaced Class, the Relocated Class, and the Obstructed-View Class. Finally, the court concluded that the district court did not abuse its discretion in declining to give appellants' proposed jury instruction. Accordingly, the court affirmed the judgment. View "Ibe v. Jones" on Justia Law

Shannon Walters sustained serious injuries when her 1995 Mazda Miata convertible overturned while she was driving it with the soft top closed. Walters filed negligence and breach of implied warranty of merchantability claims against Mazda Motor Corporation and Mazda Motor of American, Inc. (collectively, Mazda), arguing that the soft top’s latching system was defective and that she was injured after the windshield headed disconnected from the top and collapsed into the occupant compartment. The jury rendered a verdict in favor of Walters. The Supreme Court reversed, holding (1) Mazda had no legally recognized duty to design or supply a soft top that provided occupant protection in a rollover crash; and (2) the opinion offered by Walters’ expert that the Mada Miata latching system was defectively designed lacked an adequate foundation, and therefore, the circuit court abused its discretion in admitting it. Final judgment entered for Mazda. View "Holiday Motor Corp. v. Walters" on Justia Law

In 2005, Connor Libby and Elena Chapa (collectively, Defendants) signed credit card agreements with Federated Capital Corporation’s predecessor-in-interest, a Utah corporation with its principal place of business in Pennsylvania. The agreements contained a forum selection clause and choice of law provision that adopted Utah substantive and procedural law to govern any dispute under the contract. The agreements required Defendants to make monthly payments to the address specific on their billings statements, and each billing statement required Defendants to send their payments to an address in Philadelphia, Pennsylvania. Defendants defaulted in 2006. In 2012, Federated filed separate claims in separate proceedings against Defendants. In each proceeding, the district court granted summary judgment in favor of Defendants, ruling that Utah’s borrowing statute required the court to apply Pennsylvania’s four-year statute of limitations, thereby barring Federated’s claims. Federated appealed, arguing that the agreement’s forum selection clause precluded the application of Utah’s borrowing statute. The Supreme Court affirmed, holding that the borrowing statute applied to and barred Federated’s causes of action. View "Federated Capital Corp. v. Libby" on Justia Law

In 2004, buyers contracted to buy an island off of St. Thomas and a St. Thomas launch for $21,000,000 and $2,500,000. The sellers’ attorney, D’Amour, also owned the escrow company involved in the transaction. The buyers deposited $1,000,000. They later paid another $500,000 to extend the closing date. The deposits were nonrefundable. After another extension, the buyers had not paid the purchase price; the sellers had not conveyed marketable title. D’Amour sent the buyers a notice of default; they demanded refunds. The buyers sued; the sellers filed counterclaims. The district court granted summary judgment to the buyers on a conversion claim against D’Amour for $500,000. A jury awarded one buyer, Taylor, $1,500,000 in contract damages from the sellers and $46,000 for fraudulent misrepresentation by D’Amour. The jury awarded the sellers $339,516.76 from the other buyers for misrepresenting their ability to purchase the properties; the court granted judgment as a matter of law, finding the tort claims barred by the gist of the action doctrine. The court reduced Taylor’s contract damages award to $0, but upheld the fraudulent misrepresentation verdict against D’Amour The Third Circuit concluded that all parties failed to perform under the contracts and denied all damages, but concluded that Taylor was entitled to restitution from the sellers ($1,500,000). On remand, the district court awarded prejudgment interest at rates of three and six percent; declined to award attorney’s fees to Taylor, citing Taylor’s “role in breaching the contract” and the complexity of the case; and concluded that D’Amour was not entitled to attorney’s fees . The Third Circuit affirmed, except the award of prejudgment interest at a rate other than the statutorily provided 9 percent. View "Addie v. Kjaer" on Justia Law