Justia Contracts Opinion Summaries

This case centered on an agreement between the City of Rawlins, Wyoming, and Dirty Boyz Sanitation Services (Dirty Boyz) for local garbage collection and disposal. About two years after the parties executed the agreement, the State of Wyoming required Rawlins to close its landfill. Soon after, Rawlins opened a transfer station to process garbage for transport to a landfill elsewhere. Later, Rawlins adopted a flow-control ordinance requiring that all locally licensed garbage haulers take collected garbage to Rawlins’ transfer station. Dirty Boyz argued the ordinance violated the Contract Clause of the United States Constitution, and was preempted by the Federal Aviation Administration and Authorization Act (FAAAA). The district court granted summary judgment in favor of Rawlins. Finding no reversible error, the Tenth Circuit affirmed the grant of summary judgment in Rawlins' favor. View "Dirty Boyz Sanitation Service v. City of Rawlins" on Justia Law

The Supreme Court affirmed the decision of the trial court rendering judgment in favor of Plaintiff on its claim of unjust enrichment.On appeal, Defendant argued that Plaintiff’s unjust enrichment claim was barred by collateral estoppel, that Plaintiff’s recovery was precluded by law and the terms of an agreement between the parties, the trial court’s jury instructions were improper, and the trial court erred in excluding certain evidence. In affirming, the Court held that many of Defendant’s arguments were unpreserved, inadequately briefed, or both, and that Defendant was not entitled to relief on any of his assignments of error. View "MacDermid, Inc. v. Leonetti" on Justia Law

Government Code 1090, which prohibits conflicts of interest in the making of public contracts, applies to independent contractors. The Court of Appeal reversed the trial court's judgment for an LLC in an action alleging that the district breached a contract with the LLC. The district cross-complained to recover money paid under the alleged void contracts. The jury awarded millions in damages to the LLC. The court held that the trial court misinterpreted section 1090 when it instructed the jury that the LLC's contracts did not violate section 1090 on the theory that the statute did not apply to independent contractors, and erred in not instructing on the competitive bidding statutes. View "Strategic Concepts, LLC v. Beverly Hills Unified School District" on Justia Law

Dr. Susan Kegerise sought reinstatement as superintendent of the Susquehanna Township School District, as well as back pay and benefits. In January 2010, Kegerise was appointed superintendent. In 2013, the District’s Board of Directors extended Kegerise’s contract for a three-year term after agreeing, at Kegerise’s request, to include a resignation provision in her employment contract. Kegerise alleged this resignation clause was necessary to protect her interests in light of several Board members’ inappropriate behavior. Kegerise further alleged that, this clause notwithstanding, and in an effort to force her resignation, several Board members persisted in hostile actions including, inter alia, physical intimidation and verbal abuse, even after the contract was executed. In 2014, Kegerise informed the Board that she was receiving medical care and would be unable to return to work until April 21, 2014. While Kegerise was on medical leave, the Board received several letters from Kegerise’s counsel asserting that Kegerise had been constructively discharged. The Board responded by affirming that Kegerise remained the Superintendent of Schools, and that “[h]er time away from the District since that day has been recorded as sick leave derived from Dr. Kegerise’s pre-existing sick leave accumulation.” On April 17, 2014, Kegerise filed a complaint at the United States District Court, alleging, inter alia, that the Board had constructively discharged her. Kegerise asserted that, “although no formal termination has taken place, [she] cannot perform the job duties of Superintendent,” due to the Board’s behavior toward her. Kegerise sought damages in excess of six million dollars, including compensatory and economic damages “for loss of contractual salary and other emoluments of employment” and consequential damages for “damage to professional reputation and loss of future salary as an educational administrator.” The trial court held an evidentiary hearing to determine whether Kegerise had intended to resign when she filed her federal complaint, after which, it ordered the Board to reinstate Kegerise to her position with back pay and benefits. The Board appealed to the Commonwealth Court; the Commonwealth Court affirmed the trial court’s grant of mandamus. The Pennsylvania Supreme Court, however, found Kegerise did not demonstrate to a clear legal right to reinstatement. Accordingly, the orders reinstating her as superintendent with back pay and benefits was reversed. View "Kegerise v. Delgrande, et al," on Justia Law

The City of Idaho Falls (“Idaho Falls”) appealed an order dismissing its breach of contract and waste claims against H-K Contractors, Inc. (“H-K”). In 2005, H-K entered into a written contract requiring it to convey a parcel of property to Idaho Falls. The contract required that H-K initially grant Idaho Falls a storm drainage easement “over and across” the parcel. H-K was also required to convey fee title to the parcel at a future date, in no event later than March 1, 2010. H-K failed to convey the property to Idaho Falls as required. In 2016, Idaho Falls sent a letter to H-K requesting conveyance of title. H-K responded by refusing to convey title to the property, claiming that in 2009 a city official had orally informed H-K that Idaho Falls was no longer interested in the property. Based on that alleged representation, H-K decided to invest in the property to make it profitable. Idaho Falls filed a complaint against H-K for breach of contract and waste. H-K moved to dismiss the complaint based on the limitation found in Idaho Code section 5-216, alleging Idaho Falls’ claims were time barred because they were not brought within the five-year statute of limitations governing contract actions. Idaho Falls countered that the statute of limitations did not apply to it as a subdivision of the State of Idaho. On January 3, 2017, the district court dismissed Idaho Falls’ complaint as time barred. Idaho Falls timely appealed, claiming the district court erred in enforcing the five-year limitation set forth in section 5-216. The Idaho Supreme Court vacated the district court's judgment, finding it erred when it determined the term “state” in Idaho Code section 5- 216 did not include Idaho’s municipalities. Because Idaho Falls was the “state,” the district court erred when it found its contract claims against H-K were not “for the benefit of the state.” View "City of Idaho Falls v. H-K Contractors" on Justia Law

University Park hired Linear as its Village Manager through May 2015, concurrent with the term of its Mayor. In October 2014 the Village extended Linear’s contract for a year. In April 2015 Mayor Covington was reelected. In May, the Board of Trustees decided that Linear would no longer be Village Manager. His contract provides for six months’ severance pay if the Board discharges him for any reason except criminality. The Village argued that the contract’s extension was not lawful and that it owes Linear nothing. The district court agreed and rejected Linear’s suit under 42 U.S.C. 1983, reasoning that 65 ILCS 5/3.1-30-5; 5/8-1-7 prohibit a village manager's contract from lasting beyond the end of a mayor’s term. The Seventh Circuit affirmed on different grounds. State courts should address the Illinois law claims. Linear’s federal claim rests on a mistaken appreciation of the role the Constitution plays in enforcing state-law rights. Linear never had a legitimate claim of entitlement to remain as Village Manager. His contract allowed termination without cause. His entitlement was to receive the contracted-for severance pay. Linear could not have a federal right to a hearing before losing his job; he has at most a right to a hearing to determine his severance pay--a question of Illinois law. View "Linear v. Village of University Park" on Justia Law

In 2003, the Coalition Provisional Authority (CPA) was established to rule Iraq pending transfer of authority to the Iraqi Interim Government (IIG). CPA awarded Agility a Contract to operate warehouses, providing that “[t]he obligation under this contract is made with Iraqi funds.” Agility acknowledged the impending transfer of authority and CPA’s scheduled dissolution. CPA authorized the IIG Minister of Finance to delegate contract administration to CPA’s Program Management Office (PMO). CPA administered Development Fund for Iraq (DFI), composed of various sources, including revenue from sales of Iraqi petroleum and natural gas. The IIG Minister delegated contract-administration responsibility concerning DFI-funded contracts to the PMO but did not give PMO contracting authority. Subsequent Contract task orders obligated U.S. funds. A U.S. contracting officer (CO) determined that Agility owed the government $81 million due to overpayment. Separately, Agility unsuccessfully sought $47 million for unpaid fees. The Armed Services Board of Contract Appeals dismissed Agility's appeals for lack of jurisdiction under the Contract Disputes Act (CDA), 41 U.S.C. 7101–7109. The Federal Circuit affirmed. The Board’s CDA jurisdiction is limited to contracts “made by an ‘executive agency.’” CPA was not an executive agency under the CDA. CPA awarded the Contract and there was no evidence that it was novated or assigned to an executive agency. The government acted as a contract administrator, not as a contracting party. View "Agility Logistics Services Co., KSC v. Mattis" on Justia Law

Cameron and Mary Susan Arnegard appealed a trial court judgment relating to a conditional use permit (CUP) obtained from Arnegard Township in McKenzie County, North Dakota. The Arnegards argued the district court erred in granting the Township's motion in limine to exclude a buy-sell agreement; denying their motion to amend their complaint on a due process claim; granting summary judgment dismissing their breach of contract, actual fraud and equitable estoppel claims; dismissing their negligence and deceit claims by directed verdict; and determining no party prevailed in the action. The Arnegards also argued the district court abused its discretion by denying their motion to amend their complaint at trial. The Township cross-appealed, arguing the district court erred in granting judgment as a matter of law in favor of the Arnegards' due process claim. Zoning ordinances and amendments are valid if a township follows the statutory procedures. A conditional use permit does not by itself create a contract between a township and a landowner. A township has no duty to disclose validly enacted zoning ordinances or amendments beyond the notice and filing procedures provided by statute. A claim of constitutional due process violation first requires a protected property interest created by an independent source of law. The North Dakota Supreme Court affirmed the district court regarding dismissal of the Arnegards' breach of contract, actual fraud and equitable estoppel claims. The Court affirmed the judgment regarding directed verdicts in favor of the Township on the negligence and deceit claims. However, the Court reversed the judgment regarding the Arnegards' due process claim and the award of nominal damages, and remanded to the district court for further proceedings. View "Arnegard v. Arnegard Township" on Justia Law

Cameron and Mary Susan Arnegard appealed a trial court judgment relating to a conditional use permit (CUP) obtained from Arnegard Township in McKenzie County, North Dakota. The Arnegards argued the district court erred in granting the Township's motion in limine to exclude a buy-sell agreement; denying their motion to amend their complaint on a due process claim; granting summary judgment dismissing their breach of contract, actual fraud and equitable estoppel claims; dismissing their negligence and deceit claims by directed verdict; and determining no party prevailed in the action. The Arnegards also argued the district court abused its discretion by denying their motion to amend their complaint at trial. The Township cross-appealed, arguing the district court erred in granting judgment as a matter of law in favor of the Arnegards' due process claim. Zoning ordinances and amendments are valid if a township follows the statutory procedures. A conditional use permit does not by itself create a contract between a township and a landowner. A township has no duty to disclose validly enacted zoning ordinances or amendments beyond the notice and filing procedures provided by statute. A claim of constitutional due process violation first requires a protected property interest created by an independent source of law. The North Dakota Supreme Court affirmed the district court regarding dismissal of the Arnegards' breach of contract, actual fraud and equitable estoppel claims. The Court affirmed the judgment regarding directed verdicts in favor of the Township on the negligence and deceit claims. However, the Court reversed the judgment regarding the Arnegards' due process claim and the award of nominal damages, and remanded to the district court for further proceedings. View "Arnegard v. Arnegard Township" on Justia Law

This litigation began when purchasers of computer service contracts filed a putative class action against the sellers. The sellers successfully moved to compel arbitration pursuant to the terms of the computer services contracts. The sellers, in the meantime, had applied for tax abatements from the Commissioner of Revenue. The Commissioner denied the applications, and the sellers petitioned the Appellate Tax Board. Appellant, one of the consumers who purchased these service contracts, moved to intervene in the proceedings, which petition the Board allowed. The Board reversed the Commissioner’s decision and allowed the abatements. Taxes were imposed on the service contracts purchased by Appellant. After final judgment was entered in the sellers’ favor in the class action litigation, the sellers withdrew their tax abatement petitions with prejudice. The Board denied Appellant’s motion to strike the withdrawals and terminated the proceedings. The Supreme Judicial Court reversed, holding (1) the Board did not err as a matter of law in allowing the Sellers’ withdrawals; but (2) the Board’s termination of the proceedings in their entirety, after permitting Appellant to intervene and allowing the abatements, was an error of law. Rather, Appellant should have been allowed to proceed as an intervener on its claim to recover the taxes imposed on the service contracts it purchased. View "WorldWide TechServices, LLC v. Commissioner of Revenue" on Justia Law