Justia Contracts Opinion Summaries

Defendant contracted with Plaintiffs to purchase their oil recycling business. The parties carried out the purchase using three contracts. All but one of these contracts, the equipment contract, contained provisions entitling Defendant to attorney's fees in the event Plaintiffs breached the agreements. Plaintiffs later commenced this action seeking damages for Defendant's alleged breach of the contracts and for unjust enrichment. Defendant counterclaimed for breach of contract. The jury found in favor of Defendants on their counterclaim but awarded damages only with respect to Plaintiffs' breach of the equipment contract. The trial court denied Defendant's motion for attorney's fees. The appellate court reversed with respect to attorney's fees. On remand, the trial court denied Defendant's motion for attorney's fees. The appellate court affirmed. The Supreme Court reversed, holding (1) the trial court improperly applied the law of the case doctrine under these circumstances and improperly rejected Defendant's motion for attorney's fees without reaching the merits of that claim; and (2) when certain claims provide for a party's recovery of contractual attorney's fees but others do not, a party is nevertheless entitled to reasonable attorneys fees if an apportionment is impracticable because the claims arise from a common factual nucleus and are intertwined. Remanded. View "Total Recycling Servs. of Conn., Inc. v. Conn. Oil Recycling Servs., LLC" on Justia Law

The United States Postal Services (USPS) terminated Plaintiff's employment contract after discovering, through a sting operation, that Plaintiff had stolen mail containing money. The Postal Service Board of Contract Appeals (PSBCA) convened an evidentiary hearing and determined that Plaintiff's breach of his employment contract justified the decision to terminate his contract. Plaintiff did not appeal this decision. Meanwhile, Plaintiff initiated a Federal Tort Claims Act (FTCA) suit against the United States for the actions of USPS employees on the date of the sting, alleging six torts. The district court dismissed three of the claims and granted summary judgment to the government on the remaining claims. The First Circuit Court of Appeals affirmed the district court as to all claims, holding (1) the district court correctly concluded that the PSCBA's findings precluded relitigation of the factual issues in Plaintiff's FTCA suit; and (2) summary judgment was properly granted as to Plaintiff's FTCA claims for negligent supervision, malicious prosecution, and invasion of privacy by postal inspectors. View "Rios-Pineiro v. United States" on Justia Law

Merle Wood, a yacht-broker, appealed the district court's grant of summary judgment in favor of Trinity, a manufacturer and seller of yachts. Merle Wood sued Trinity for, among other things, quantum meruit and unjust enrichment. Merle Wood alleged that Trinity refused to pay for the fair, reasonable value of the benefit it provided in brokering a deal that led to Trinity selling two multi-million dollar yachts. The court held that Merle Wood's quantum meruit and unjust enrichment causes of action were time-barred under Fla. Stat. 95.11. Accordingly, the court affirmed the district court's grant of summary judgment in favor of Trinity. View "Merle Wood and Assoc., Inc v. Trinity Yachts, LLC" on Justia Law

Plaintiff, on behalf of herself and the Estate, challenged the district court's grant of summary judgment to Zenith on the Estate's breach of the insurance contract claim. After review and oral argument, the court certified questions to the Florida Supreme Court: (1) Does the estate have standing to bring its breach of contract claim against Zenith under the employer liability policy? (2) If so, does the provision in the employer liability policy which excludes from coverage "any obligation imposed by workers' compensation . . . law" operate to exclude coverage of the estate's claim against Zenith for the tort judgment? (3) If the estate's claim was not barred by the workers' compensation exclusion, does the release in the workers' compensation settlement agreement otherwise prohibit the estate's collection of the tort judgment? View "Morales v. Zenith Ins. Co." on Justia Law

After Defendant failed to repay a loan Plaintiff made to him in the amount of $8,500, Plaintiff filed a complaint against Defendant alleging breach of contract and breach of an implied-in-fact contract. Plaintiff later amended his complaint to include a claim for failure to repay based on book account. After a jury, the trial justice ordered Defendant to pay damages to Plaintiff in the amount of $8,500. Defendant appealed, contending that the trial justice erred in finding that Plaintiff was a credible witness and in failing to find that the transaction was void because Plaintiff had allegedly advanced the money to Defendant with the knowledge that it would be used for gambling. The Supreme Court affirmed, holding that the Court had no choice but to uphold the lower court's findings because the Court was not provided with a transcript of the trial below and therefore was unable to properly engage in a review of the trial justice's factual findings. View "Vogel v. Catala" on Justia Law

Mortgage Electronic Registration Systems, as nominee for two lenders (collectively, Plaintiffs), held mortgages on Lot 456. For the property owner's failure to pay his water bill, the Pawtucket Water Supply Board (PWSB) auctioned the lot. PWSB issued a deed conveying the title in the property to Amy Realty. Amy Realty subsequently discovered that the property PWSB had intended to auction had been mistakenly listed as Lot 486 on the tax sale notices and deed. Amy Realty then obtained a corrective deed from the PWSB conveying title to Lot 456. Amy Realty subsequently filed a petition to foreclose on Plaintiffs' rights of redemption in Lot 456. Plaintiffs filed this action seeking to vacate the final decree of disclosure, alleging that the corrective deed changing the lot number from 486 to 456 was invalid and this infirmity rendered the foreclosure decree void. The superior court granted summary judgment for Plaintiffs. The Supreme Court affirmed, holding (1) the corrective deed obtained in this case was null and void because it was not recorded within sixty days of the tax sale; and (2) the final foreclosure decree may be vacated because the tax sale was invalid. View "Mortgage Elec. Registration Sys., Inc. v. DePina" on Justia Law

Plaintiff borrowed $249,900 from Lehman Brothers Bank to finance the purchase of a home, and he signed an adjustable rate note that evidenced the debt. Plaintiff and his wife (Plaintiffs) then executed a mortgage on the property that secured the loan. Even though the note was made payable to the lender, the mortgage was granted to Mortgage Electronic Registration Systems, Inc. (MERS) as nominee for the lender and the lender's subject and assigns. Plaintiffs subsequently defaulted on the note, and MERS initiated foreclosure proceedings. Plaintiffs subsequently commenced an action seeking to prevent MERS from exercising the power of sale contained in the mortgage, arguing that only a mortgagee was permitted to exercise the power of sale and that MERS was merely a nominee-mortgagee without the authority to foreclose. The superior court denied Plaintiffs' request and entered judgment on behalf of Defendants. The Supreme Court affirmed, holding that MERS had both contractual and statutory authority to foreclose and exercise the power of sale. View "Bucci v. Lehman Bros. Bank, FSB" on Justia Law

Seller and his real estate agent (Agent) entered into an agency agreement requiring Agent to inform potential buyers of material defects in Seller's home of which she had actual knowledge. Seller completed a signed a seller's disclosure form. After Buyers purchased the home, Buyers filed this lawsuit against Seller, Agent, and Agent's brokerage firm (Firm), alleging, inter alia, fraud, negligent misrepresentation for providing false representations in the disclosure form, breach of contract, and violations of the Kansas Consumer Protection Act (KCPA). The district court granted summary judgment for Defendants on all claims. The court of appeals reversed the district court's summary judgment in favor of Seller and affirmed summary judgment in favor of Agent and Firm. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) erred in granting summary judgment to Seller on Buyers' fraudulent inducement, fraud by silence, negligent misrepresentation, and breach of contract claims; and (2) erred in granting summary judgment to Agent and Firm for Buyers' negligent misrepresentation and KCPA claims. Remanded. View "Stechschulte v. Jennings" on Justia Law

Plaintiff filed a lawsuit against his employer, Union Pacific, for injuries he sustained at a railyard operated by Gunderson. Union Pacific filed a third-party complaint for indemnity against Gunderson, and Union Pacific and Gunderson settled with plaintiff, each agreeing to pay half of plaintiff's settlement demand. After settling with plaintiff, Union Pacific and Gunderson proceeded to trial to determine whether Gunderson should also be liable for Union Pacific's half of the settlement. The court affirmed the district court's award to Union Pacific of half of its attorney's fees and costs incurred as of the settlement pursuant to the parties' Track Lease Agreement but denied Union Pacific's motion for additional attorney's fees arising out of the post-settlement indemnification proceedings. View "Rice v. Union Pacific RR Co." on Justia Law

The Thornhocks filed an action against the Esterholdts and others seeking to quiet title to certain lands in Lincoln County. The district court granted summary judgment to the Thornocks as to some of the land but denied summary judgment as to a certain strip of property. After a bench trial, the district court quieted title in the disputed strip of land in the Esterholdts. The Supreme Court affirmed, holding (1) an appurtenant easement was not created by a deed that granted, in addition to tracts of fee title land, also that "right of way to be used in connection with said land"; and (2) an appurtenant easement was not created by a deed that granted a "right-of-way" described as the land now in question. View "Thornock v. Esterholdt" on Justia Law