Justia Contracts Opinion Summaries

The case involves the Indian Self-Determination and Education Assistance Act (ISDA), which allows an Indian tribe to enter into a "self-determination contract" with the Indian Health Service (IHS) to administer healthcare programs that IHS would otherwise operate for the tribe. The San Carlos Apache Tribe and the Northern Arapaho Tribe sued the Government for breach of contract, arguing that although they used the Secretarial amount and program income to operate the healthcare programs they assumed from IHS under their self-determination contracts, IHS failed to pay the contract support costs they incurred by providing healthcare services using program income. The Ninth and Tenth Circuits concluded that each Tribe was entitled to reimbursement for such costs.The Supreme Court of the United States affirmed the decisions of the Ninth and Tenth Circuits. The Court held that ISDA requires IHS to pay the contract support costs that a tribe incurs when it collects and spends program income to further the functions, services, activities, and programs transferred to it from IHS in a self-determination contract. The Court reasoned that the Tribe's self-determination contract incorporated ISDA, which required the Tribe to spend third-party program income on healthcare. Those portions of the Tribe’s healthcare programs funded by third-party income thus constituted “activities which must be carried on by [the Tribe] as a contractor to ensure compliance with the terms of the contract,” and the contract support costs associated with those activities were incurred “in connection with the operation of the Federal program.” The Court concluded that the text of ISDA, therefore, indicated that IHS was required to reimburse the Tribe for those costs. View "Becerra v. San Carlos Apache Tribe" on Justia Law

The case involves a dispute between Mary Roth and Gary Meyer, who were in a long-term relationship but never married. They cohabitated and ran a cattle operation together on a property that had a complex ownership history involving various members of Meyer's family. The couple's relationship ended, and Roth sued Meyer, alleging that he had converted some of her cattle and failed to repay loans she had given him.The District Court of Grant County, South Central Judicial District, found in favor of Roth. It ruled that Meyer had gained title to the disputed property through adverse possession and had transferred it to Roth in 2010. The court also found that Meyer had converted 13 of Roth's cattle and breached oral loan agreements with her, ordering him to pay her $52,500.On appeal, the Supreme Court of North Dakota reversed the lower court's decision. It found that the lower court had erred in its findings on adverse possession, the admissibility of certain evidence, the timing of the alleged conversion of cattle, the valuation of the converted cattle, and the enforceability of the loan contracts. The Supreme Court remanded the case to the lower court for further proceedings, instructing it to make new findings based on the existing record. View "Roth v. Meyer" on Justia Law

The case involves Mid Valley Pipeline Company, an interstate pipeline company, and the Board of Mississippi Levee Commissioners. In 1949, the Levee Board granted Mid Valley a permit to construct and maintain two pipelines across a levee in Mississippi. The permit was not limited to a term of years and could be revoked by the Levee Board if Mid Valley failed to comply with any of the permit's conditions. In 2005, Mid Valley was instructed to relocate its pipelines, which it did at a cost of over $700,000. In 2020, the Levee Board informed Mid Valley that it would be charging an annual pipeline crossing fee and would revoke all existing permits for pipelines not currently paying the fee. Mid Valley did not respond to these notices.The United States District Court for the Northern District of Mississippi granted summary judgment in favor of the Levee Board, dismissing Mid Valley's claim that the imposition of the annual fee and the revocation of the permit violated the Contract Clause of the United States Constitution. The court reasoned that the 1949 permit was not a contract.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The appellate court agreed with the district court that the 1949 permit was not a contract. The court noted that under Mississippi law, a contract requires mutual assent, among other elements. The court found that the permit was a unilateral grant of permission by the Levee Board, and there was no evidence of mutual assent to form a contract. Therefore, the Levee Board's actions did not violate the Contract Clause. View "Mid Valley Pipeline v. Rodgers" on Justia Law

In this case, Amy Bricker, a high-ranking executive, moved from Cigna Corporation to CVS Pharmacy, Inc., both of which are major healthcare conglomerates. Cigna sued Bricker and CVS, seeking to enforce a non-compete agreement that Bricker had signed while employed at Cigna. The district court granted a temporary restraining order and a preliminary injunction to preserve the status quo and protect Cigna's business interests. Bricker and CVS appealed the preliminary injunction.Previously, the district court had found that Cigna's protected interests were numerous and substantial, spanning multiple lines of products and services. It also found that Bricker likely retained a considerable amount of protected information from her time at Cigna. The court concluded that Cigna had a fair chance of demonstrating that the non-compete agreement was reasonable and enforceable under Missouri law.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court agreed with the lower court's findings and concluded that the non-compete agreement was likely enforceable under Missouri law. The court also found that Cigna would likely suffer irreparable harm if the preliminary injunction was not granted, as Bricker could potentially disclose Cigna's trade secrets to CVS. The court concluded that the balance of equities favored Cigna and that the public interest supported the enforcement of contractual obligations. Therefore, the court held that the district court did not abuse its discretion in granting the preliminary injunction. View "Cigna Corporation v. Bricker" on Justia Law

This case involves a dispute between the City of Great Falls and the Board of Commissioners of Cascade County, Montana, over the interpretation of a 1975 interlocal agreement that established a consolidated City-County Health Board. The disagreement arose after the Montana Legislature enacted new laws in 2021 that changed the governance of local health boards. The County argued that the new laws required the County Commission to be the governing body of the Health Board, while the City maintained that the 1975 agreement allowed the City mayor to be a full voting member of the Health Board.The District Court of the Eighth Judicial District ruled in favor of the City, finding that the 1975 agreement allowed the City mayor to be a full voting member of the Health Board and that the Health Board was the "local governing body" referenced in the new laws. The County appealed this decision to the Supreme Court of the State of Montana.The Supreme Court affirmed the District Court's decision. It held that the District Court did not adjudicate a non-justiciable political question and correctly interpreted the 1975 agreement and the new laws. The Supreme Court found that the 1975 agreement allowed the City mayor to be a full voting member of the Health Board and that the Health Board was the "local governing body" referenced in the new laws. The Court also held that the new laws did not moot the issues at stake in the case. View "City of Great Falls v. Cascade County Commissioners" on Justia Law

The case involves plaintiffs Christopher Calise and Anastasia Groschen, who alleged that they were harmed by fraudulent third-party advertisements posted on Meta Platforms, Inc.'s (commonly known as Facebook) website, in violation of Meta's terms of service. Meta claimed immunity from liability under § 230(c)(1) of the Communications Decency Act (CDA), which applies to a provider or user of an interactive computer service that a plaintiff seeks to treat, under a state law cause of action, as a publisher or speaker of information provided by another information content provider.The district court dismissed the plaintiffs' non-contract claims, ruling that they were barred by § 230(c)(1) of the CDA. The court also dismissed the plaintiffs' contract-related claims, holding that Meta's duty arising from its promise to moderate third-party advertisements was related to Meta's status as a "publisher or speaker" of third-party advertisements, and therefore § 230(c)(1) barred the plaintiffs' contract claims.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal of the plaintiffs' non-contract claims, agreeing that these claims derived from Meta's status as a "publisher or speaker" of third-party advertisements. However, the appellate court vacated the dismissal of the plaintiffs' contract-related claims, holding that Meta's duty arising from its promise to moderate third-party advertisements was unrelated to Meta's status as a "publisher or speaker" of third-party advertisements, and therefore § 230(c)(1) did not bar the plaintiffs' contract claims. The case was remanded for further proceedings. View "Calise v. Meta Platforms, Inc." on Justia Law

In this case, a Delaware statutory trust, NB Taylor Bend, DST (Taylor Bend), borrowed $13 million from Prudential Mortgage Capital Company, LLC (Prudential) to acquire property in Lafayette County, Mississippi. Patrick and Brian Nelson, who were guarantors of the loan, signed an Indemnity and Guaranty Agreement (the Guaranty) in December 2014, personally guaranteeing the loan. After the loan documents were executed, Prudential assigned the loan to Liberty Island Group I, LLC (Liberty), which in turn assigned the loan to North American Savings Bank, FSB (NASB). By May 2020, Taylor Bend struggled to find tenants for the property due to the COVID-19 pandemic and informed NASB of their financial problems. In May 2021, NASB declared Taylor Bend to be in default after the borrower continually failed to make timely loan payments. NASB then filed an action against the Nelsons in the United States District Court for the Northern District of Mississippi, asserting claims for breach of the Guaranty, for recovery of the loan balance, and for declaratory judgment.The district court entered partial summary judgment for NASB, holding the Nelsons “breached the [G]uaranty and thus owe[d] to [NASB] the amount remaining due on the subject loan.” The court determined that the Guaranty was “freely assignable” and that Prudential adequately assigned all of its rights and interests to Liberty, which in turn assigned all of its rights and interests to NASB, including those conferred by the Guaranty. The court also concluded that the defenses raised by the Nelsons were “unavailable given the borrower’s absence from this litigation.” The court also granted Brian’s motion for summary judgment against Patrick, ruling that the indemnity agreement between the brothers was valid and binding and that Patrick was contractually required to indemnify Brian for “any and all obligations arising out of or relating to this litigation.”The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court held that the Guaranty was properly assigned from Prudential to Liberty and from Liberty to NASB. NASB could therefore properly bring its claims for breach of guaranty and declaratory judgment against the Nelsons to recover the loan deficiency. Moreover, under Mississippi law, Patrick may not interpose equitable defenses that were available only to Taylor Bend to defeat his liability under the Guaranty. The court also held that the deficiency judgment awarded to NASB pursuant to the Guaranty need not be reduced by the third-party sale of the Apartments to Kirkland. NASB had no duty to mitigate its damages under either Mississippi law or the terms of the Guaranty. View "North American Savings Bank v. Nelson" on Justia Law

The case involves Robert James McCabe, a former sheriff of the City of Norfolk, Virginia, who was convicted of carrying out fraud and bribery schemes with contractors concerning medical and food services for prisoners in the Norfolk Jail. Over 20 years, McCabe provided favored contractors with inside information about competing bids for the Jail’s contracts, altered and extended contracts for their benefit, and received various things of substantial value in return. McCabe was convicted of 11 federal offenses, including charges of conspiracy, honest services mail fraud, Hobbs Act extortion, and money laundering. He was sentenced to 144 months in prison, plus supervised release.McCabe appealed his convictions and sentences, raising four contentions of error. He argued that his trial was unfairly conducted before a trial of a co-defendant, that the trial court erred by admitting hearsay statements, that the jury instructions were incorrect, and that the court wrongly applied an 18-level sentencing enhancement. The United States Court of Appeals for the Fourth Circuit rejected all of McCabe’s contentions and affirmed his convictions and sentences. View "US v. McCabe" on Justia Law

In North Dakota, Donavon Meuchel approached MR Properties LLC, a company with two members, Jessy Meyer and Nick Renner, to purchase the Golden West Shopping Center. Meuchel offered the asking price of $600,000. A real estate broker prepared a purchase agreement, but MR Properties did not sign any version of it. During negotiations, it was discovered that part of the shopping center encroached on a neighboring parcel of land owned by MKB LLP. Meuchel requested MR Properties to acquire additional land from MKB and include it in the purchase. However, negotiations broke down when MR Properties discovered that Meuchel had instructed a surveying company to modify the location of a previously agreed upon boundary line. MR Properties returned Meuchel’s earnest money, stating that an agreement could not be reached.The District Court of Morton County treated MR Properties' motion to dismiss as a motion for summary judgment. The court disregarded statements in Meuchel’s affidavit and struck a late-filed supplemental affidavit. The court concluded that Meuchel failed to meet his burden to show specific performance was necessary and granted summary judgment to MR Properties, dismissing Meuchel’s claim for specific performance.The Supreme Court of North Dakota affirmed the lower court's decision. The court found that the district court did not abuse its discretion in disregarding statements in an affidavit and in striking a late-filed supplemental affidavit. The court also concluded that the district court did not err in granting summary judgment to MR Properties. The court held that the record did not provide any "clear and unequivocal" evidence showing a meeting of the minds or mutual consent between the parties to establish an oral contract. Therefore, the court affirmed the judgment dismissing Meuchel’s claim for specific performance. View "Meuchel v. MR Properties" on Justia Law

The case involves Bristol SL Holdings, Inc., the successor-in-interest to Sure Haven, Inc., a defunct drug rehabilitation and mental health treatment center, and Cigna Health and Life Insurance Company and Cigna Behavioral Health, Inc. Bristol alleged that Sure Haven's calls to Cigna verifying out-of-network coverage and seeking authorization to provide health services created independent contractual obligations. Cigna, however, denied payment based on fee-forgiving, a practice prohibited by the health plans. Bristol brought state law claims for breach of contract and promissory estoppel against Cigna.The district court initially dismissed Bristol’s claims, but the Ninth Circuit Court of Appeals reversed the dismissal, holding that Bristol had derivative standing to sue for unpaid benefits as Sure Haven’s successor-in-interest. On remand, the district court granted Cigna’s motion for summary judgment, ruling that the Employee Retirement Income Security Act of 1974 (ERISA) preempted Bristol’s state law claims.On appeal, the Ninth Circuit Court of Appeals affirmed the district court's decision. The court held that Bristol’s state law claims were preempted by ERISA because they had both a “reference to” and an “impermissible connection with” the ERISA plans that Cigna administered. The court reasoned that Bristol’s claims were not independent of an ERISA plan because they concerned the denial of reimbursement to patients who were covered under such plans. The court also held that allowing liability on Bristol’s state law claims would interfere with nationally uniform plan administration, a central matter of plan administration. View "Bristol SL Holdings, Inc. v. Cigna Health and Life Insurance Co." on Justia Law