Justia Contracts Opinion Summaries

Petitioner Arnold Calderon was injured in a vehicle accident with an uninsured motorist. At the time, petitioner was insured with respondent American Family Mutual Insurance. American Family paid the policy limit to petitioner's medical providers; it denied payment with respect to his uninsured/underinsured (UM/UIM), disputing the amount of petitioner's damages. A jury returned an award in petitioner's favor. The trial court offset the amount of the jury award by the amount already paid to the medical providers. Petitioner argued on appeal of that offset, that the "MedPay" coverage was separate from the UM/UIM coverage, and that the MedPay amount should not have been deducted. The Supreme Court reversed, finding that the amount of UM/UIM coverage, as listed in petitioner's policy, in this case should not have been reduced by the MedPay amount. View "Calderon v. American Family Mutual Insurance Company" on Justia Law

Vernon Smith appeals the district court’s award of attorney fees to Treasure Valley Seed Company, LLC and its owner Don Tolmie (collectively TVSC). This case arose out of a contract for the sale of lima beans between Victoria H. Smith and TVSC. In 2013, Victoria’s son, Vernon, filed a complaint against TVSC alleging claims for breach of the lima beans contract. As plaintiff, the complaint named “VICTORIA H. SMITH, by and through her attorney in fact, Vernon K. Smith, by and through his Durable and Irrevocable Power of Attorney.” In 2014, TVSC learned Victoria had died on September 11, 2013—roughly three months before the complaint was filed. TVSC then moved to dismiss the complaint, contending there was no real party in interest. Vernon responded and argued he was the real party in interest because of his durable and irrevocable power of attorney. The district court concluded Vernon’s power of attorney had terminated at Victoria’s death. Further, the district court reasoned that because no personal representative had been appointed through probate, there was no real party in interest. Accordingly, the district court granted TVSC’s motion to dismiss. Vernon appealed. The Supreme Court found, after review of this matter: (1) there was indeed a real party in interest; and (2) the district court erred by assessing attorney fees jointly and severally against Victoria and Vernon. The matter was remanded for further proceedings. View "Smith v. Treasure Valley Seed Co." on Justia Law

Appellants DOT Compliance Service (“DOT Compliance”), Jeff Minert, David Minert, and Ryan Bunnell appealed a jury verdict finding that DOT Compliance and Bunnell tortiously interfered with Respondent Drug Testing Compliance Group, LLC’s (“DTC Group’s”) customer contracts and that Jeff and David Minert violated the covenant of good faith and fair dealing by disparaging DTC Group in violation of a settlement agreement entered into by the parties. DTC Group brought this suit alleging that DOT Compliance, through its owners and employees was calling DTC Group’s customers, asking them to cancel their service, and making disparaging comments about DTC Group. after careful consideration of the trial court record, the Supreme Court found that the trial court erred: (1) in denying Appellants' motion for a directed verdict on the tortious interference with contract claim; and (2) in denying Appellants' motion for JNOV on the breach of implied good faith and fair dealing claim against Jeff and David Minert. The trial court judgment was reversed and the matter remanded for further proceedings. View "Drug Testing Compliance Grp v. DOT Compliance Service" on Justia Law

The City of Chattanooga added a cost-of-living adjustment (COLA) to its Fire and Police Pension Fund in 1980. In 2000, the city amended the COLA for a third time to create a fixed three-percent annual increase in retirement benefits. The city amended the COLA again in 2014 to a lower, variable annual increase. Fund participants challenged the 2014 amendment under the Contract Clause, claiming a right to the fixed three-percent COLA. The district court granted the defendants summary judgment. The Sixth Circuit affirmed. There is no unmistakable evidence of the city’s intent to be bound to the fixed COLA, because the COLA is neither vested nor accrued within the meaning of the City Code. Absent some clear indication that the legislature intends to bind itself contractually, a statute does not create a contractual relationship. The City Code contains one vesting provision: After 10 years of service, a participant has the right either to a full refund of her contributions or to retirement benefits upon turning 55. The section does not mention the COLA. The fact that the Fund described the fixed three-percent COLA as “guaranteed” when enacting the 2000 amendment does not prove that the city intended to be bound to the fixed COLA. View "Frazier v. City of Chattanooga" on Justia Law

Jon and Winifred Prime brought suit against Dawn Harlor stemming from a dispute over the Primes’ right to use a dock according to an easement Harlor had granted the the Primes. At all relevant times, Harlor was insured by Amica Mutual Insurance Company under a homeowner’s insurance policy providing that Amica would defend Harlor against claims that may result in covered damages. Amica denied Harlor’s request that Amica provide a defense in the underlying suit based on its conclusion that the suit could not result in covered damages. After Harlor settled the suit with the Primes, Harlor brought suit against Amica alleging that Amica breached the policy by failing to defend her in the underlying lawsuit. The superior court granted summary judgment for Amica, concluding that any damages that might have resulted from the underlying suit would not be covered by Harlor’s policies and, therefore, did not give rise to a duty to defend. The Supreme Court vacated the summary judgment and remanded for the entry of summary judgment in favor of Harlor, holding that Amica breached its duty to defend. Remanded for further proceedings regarding Amica’s duty to indemnify Harlor for any or all of the amount that she paid to settle the underlying action. View "Harlor v. Amica Mutual Insurance Co." on Justia Law

In 1996, Matthew Cote accepted an employment opportunity with Richmond Ready-Mix (RRM) when John Aiello explained that Plaintiff could purchase RRM in the future. Over the years, Aiello repeatedly assured Cote that he would purchase RRM. In 2005, Aiello sold RRM to Peter Calcagni. Cote subsequently filed an action against the John and Anna-Maria Aiello (together, the Aiellos) alleging breach of an implied contract, promissory estoppel, unjust enrichment, fraud, and negligent misrepresentation. The trial justice found for the Aiellos on all claims, concluding that Cote failed to prove the existence of an implied contract to purchase RRM and that Aiello’s promises to Plaintiff did not support a claim for promissory estoppel. The Supreme Court affirmed, holding that the trial justice did not overlook or misconceive material evidence and was not otherwise clearly wrong in dismissing the complaint. View "Cote v. Aiello" on Justia Law

The district court granted summary judgment dismissing the negligence, contract, and fraud claims brought by Path to Health, LLP (“Path”) against Daren Long and ALL-IN INC. d/b/a RE/MAX ALL-IN REALTORS (collectively “Realtors”). Path’s claims were based on the allegation that Long misrepresented that property Path purchased was zoned for commercial use when it was actually zoned for residential use. After review, the Supreme Court found that the district court erred in dismissing Path's breach of contract claim because Idaho Code section 54-2087 was incorporated into the Buyer Representation Agreement at issue in this case. Further, the Court found the district court erred in dismissing Path's fraud claim because it found issues of fact as to whether Path justifiably relied upon Long's representations. The Court reversed on those two issues, but affirmed as to all others. The case was remanded for further proceedings. View "Path to Health, LLP v. Long" on Justia Law

Appellant Greenville Country Club, through its workers’ compensation carrier, Guard Insurance (“Guard”), appealed a Superior Court Order affirming a decision of the Industrial Accident Board (the “Board”). While working for Greenville Country Club, Jordan Rash suffered injuries to his lumbar spine in two separately compensable work accidents. The first accident occurred in 2009 while the country club was insured by Guard Insurance Group. The second accident occurred in 2012 while the country club was insured by Technology Insurance (“Technology”). In 2014, Rash filed two Petitions to Determine Additional Compensation, one against Guard and one against Technology. After a hearing, the Board determined that the condition at issue was a recurrence of the 2009 work injury and not an aggravation of the 2012 work injury, and concluded that Guard was therefore wholly liable for the additional compensation to Rash. Guard appealed, arguing: (1) the Board failed to properly apply the rule for determining successive carrier liability; and (2) there was no substantial evidence to support the Board’s finding that Rash fully recovered from the 2012 accident or that his ongoing condition was solely caused by the 2009 work accident. After review, the Delaware Supreme Court found no error in the Board’s decision, and that the decision was supported by substantial evidence. Accordingly, the Court affirmed the Board's decision. View "Greenville Country Club (Guard Insurance) v. Greenville Country Club (Technology Insurance)" on Justia Law

The issue in this appeal centered on whether a force majeure clause in a written contract between the county and a developer did not apply to the developer’s failure to obtain zoning approval in order to construct the cement plant required in the agreement. After review of the contract and the clause at issue here, the Supreme Court held that the clause was broad enough to apply. Accordingly, the Court vacated the district court's judgment and remanded this case for further proceedings. View "Burns Concrete, Inc v. Teton County" on Justia Law

This appeal centered on the legality of a Joint Powers Agreement (“JPA”) entered into in 2003 between the Independent Highway District (“IHD”) and the City of Sandpoint (“City”) to settle litigation between the two. The JPA provided for the City to assume control of all streets in the City and for IHD to pay over to the City all highway ad valorem taxes collected on property in the city limits. After the parties had operated under the JPA for ten years, IHD notified the City that, upon reflection, it had determined the JPA was legally void and that it would no longer pay its share of the property taxes to the City. The City filed suit against IHD for breach of contract and sought both a declaratory ruling that the JPA was valid and an order enjoining IHD from interfering with the City’s control of the streets within city limits. The district court ruled in favor of the City on summary judgment and granted attorney fees. IHD appealed. Finding that the JPA was void and unenforceable (violating Idaho Code section 67-2328), the Supreme Court reversed the trial court's judgment and remanded this case for for the trial court to unwind the relationship between the parties. View "City of Sandpoint v. Independent Hwy Dist" on Justia Law