Justia Contracts Opinion Summaries

Conoco appealed the district court's judgment confirming an arbitration award favorable to Rain. Conoco and Rain were parties to a long-term supply agreement, whereby Conoco agreed to sell all green anode coke produced at one of its refineries during a certain time period. The court held that, given the considerable deference afforded arbitration awards, Conoco's argument that the arbitrator exceeded his powers by failing to select only one proposal, which relied on paragraphs stricken from the final award in accordance with the Commercial Rules, must fail. The court also held that vacatur was no appropriate and the award must be enforced where the arbitrator laid out the facts, described the contentions of the parties, and decided which of the two proposals should prevail.

Majorie Bedessem, as trustee of her revocable trust, filed a complaint against David and Susan Cunningham, seeking enforcement of an easement across the Cunningham property to access the Bedessem property. Bedessem claimed an implied access easement or, in the alternative, access pursuant to the restrictive covenants applicable to both properties. The district court granting Cunninghams' summary judgment motion after finding no evidence of an implied easement and that the restrictive covenants authorized only the Architectural Control Committee to sue for enforcement of the covenants. The Supreme Court affirmed, holding that the district court did not err when it ruled that Bedessem did not have standing to enforce a restrictive covenant against Cunninghams, as the covenants granted the Architectural Control Committee the sole right to enforce the covenants.

Janice Willis executed a general warranty deed reserving a life estate in her home for herself and conveying the remainder to her Eddie in fee simple. While Janice was still alive, Eddie died, and his interest passed to his children. Janice subsequently sought reformation of the deed based on unilateral mistake of the grantor in the absence of fraud. The trial judge granted a directed verdict for Defendants. The court of appeals affirmed. The Supreme Court modified and affirmed the decision of the court of appeals, holding that, under Crawford v. Willoughby and its progeny, reformation of a deed was unavailable as a remedy in this case.

Oscar Armendariz, the owner of a tract of land subject to eminent domain proceedings, appealed the district court's order determining the final distribution of an appraisers' award. Armedariz contended the district court erred in distributing a portion of the award based on quantum meruit to Vernon Jarboe, the attorney for Richard and Angela Britt, who were formerly interested parties to the eminent domain proceeding. The Supreme Court reversed the district court's award, holding that the district court lacked statutory authority to award fees to Jarboe. Remanded with directions to enter an order distributing the entire amount of the award in favor of Armendariz.

The dispute in this case revolved around a limited partnership (Kellom Heights) formed to provide financing for the redevelopment of property. Appellees were Kellom Heights, a corporation, and limited partners in Kellom Heights. Appellants were the redevelopment corporation, the general partner, and a corporation that was a limited parter of the redevelopment corporation. Appellees became dissatisfied with the operation of Kellom Heights and filed this complaint asserting various causes of action. The district court found for Appellees on certain causes of action and entered a judgment in their favor in the amount of $918,228 plus costs and interest. The court also awarded attorney fees and denied Appellees' request for prejudgment interest. The Supreme in part reversed and remanded, holding (1) the district court erred when it rejected Appellants' statute of limitations defenses as to certain claims; and (2) the court erred in ruling that additional supervisory fees were not permitted. The Court affirmed the remainder of the district court's judgment.

Appellant, R.L. Turner Corporation, filed suit against Appellee, the Town of Brownsburg. The court subsequently granted Appellee's petition for attorneys' fees. The court of appeals affirmed. Appellant appealed, contending, principally, that the trial court lacked jurisdiction to enter the order on fees because entering a final judgment terminates a trial court's jurisdiction and the order granting Appellee's motion to dismiss constituted a final judgment. The Supreme Court affirmed, holding that the trial court did not err in awarding the petition, and noting that jurisdictional concepts were the wrong analytical tool for determining whether an Indiana trial court's post-judgment action was a valid exercise of its authority.

The town manager of the Town of Freeport signed a contract transferring the Town's emergency dispatch services to another town. Plaintiffs, two Town residents, filed an amended complaint requesting a declaratory judgment that the contract was void because it was inconsistent with section 6.10 of the Town's charter, which provides that multi-year contracts must be "made or approved by ordinance," and seeking an injunction. The Town Council later voted in favor of an ordinance that ratified the contract. The superior court subsequently dismissed the complaint, finding that the case was moot because the Town had approved the outsourcing contract by ordinance, thereby complying with section 6.10. The Supreme Court vacated the judgment and held (1) the court erred by dismissing the amended complaint because the passage of the ordinance ratifying the transfer of dispatch services contract did not render the case moot, as the contract did not conclude until the year 2016; but (2) the passage of the ordinance did satisfy the "made or approved by ordinance" requirement of section 6.10 of the charter. Remanded for entry of a judgment in favor of the Town on the merits of the amended complaint and denying the request for an injunction.

Galen Porter was the sole shareholder in County Forest Products. Porter began operating a fuel delivery business as Porter Cash Fuel but never registered that name with the Secretary of State. Porter ordered fuel and gas from A.E. Robinson in a series of transactions that continued for three years. Ultimately, the business relationship deteriorated, and A.E. Robinson refused to deliver any more products. A.E. Robinson sued County Forest and Porter seeking payment on the account. Following a non-jury trial, the court entered judgment for A.E. Robinson jointly and severally against County Forest and Porter in the amount of the invoices plus financing charges and attorney fees. The Supreme Court modified the judgment to remove the award of attorney fees and affirmed as modified, holding that the trial court (1) properly held Porter and County Forest jointly and severally liable; but (2) erred in awarding attorney fees to A.E. Robinson pursuant to Me. Rev. Stat. 2-207.

Lamar Hooker appealed a chancery court's grant of Stephen Greer's Motion for Partial Summary Judgment, in which the court awarded attorney's fees to Greer based on Hooker's improper filing of a lis pendens, and Greer's Motion for Summary Judgment on Hooker's counterclaim. Greer and Hooker knew each other for more than thirty years, having worked together in multiple business ventures. In early 2002, Greer and Hooker entered into an agreement for the purchase, development, and sale of two tracts of land to which each made monetary contributions and participated in certain decisions regarding the development and marketing of the properties. In September 2003, Greer sent a letter to Hooker in which he cancelled their business arrangement. In this letter, he characterized the relationship as a "proposed joint venture" and declared such proposed venture "null and void." Greer claimed the venture was predicated on Hooker's ability to put up one half of the initial capital investment to purchase the properties, and that Hooker had failed to do so. Upon review, the Supreme Court affirmed the trial court's finding that the lis pendens was improperly filed. However, because the trial court based the attorney's fees award on an improper interpretation of the Litigation Accountability Act, the Court reversed the judgment, vacated the award, and remanded for further consideration. Finally, the Court affirmed the trial court's grant of summary judgment for Greer on Hooker's counterclaim, holding that his claim was subject to a three-year statute of limitations and was thus time-barred.

Dr. Carroll Meador filed a complaint against Mississippi Baptist Health Systems, Inc. (MBHS), Trustmark National Bank (Trustmark), and Doe Defendants 1 through 10, for breach of fiduciary duties, interference with fiduciary duties, interference with contract rights, interference with prospective business advantage, intentional infliction of emotional distress, deceit, fraud, and retaliatory discharge. The complaint stemmed from the doctor's employment with MBHS and a large line of credit he obtained from Trustmark. A dispute between the parties ended with the bank suing the doctor for defaulting on the loan, and the doctor declaring bankruptcy. Several defendants sought to remove the case to the federal district court. The district court granted remand of the case, finding the federal bankruptcy proceedings in the case had been concluded and only state claims remained. Then Defendants Trustmark, MBHS and several codefendants filed a motion for summary judgment and motion to dismiss. The doctor appealed the ultimate outcome of the trial court's decision in favor of Defendants. Upon review, the Supreme Court found that the trial court abused its discretion in refusing to strike portions of the doctor's affidavit, and in denying Trustmark and MBHS' motions for summary judgment. The Court reversed the trial court's decision and remanded the case for further proceedings.