Justia Contracts Opinion Summaries

The case involves Hahnenkamm, LLC and the United States Forest Service. Hahnenkamm sold a parcel of land to the Forest Service. The purchase price was based on an appraisal that was supposed to comply with the Uniform Appraisal Standards for Federal Land Acquisitions, also known as the Yellow Book. Hahnenkamm later sued the Forest Service, claiming that the appraisal did not comply with the Yellow Book and was not independent, thus breaching the purchase agreement.The United States Court of Federal Claims found in favor of Hahnenkamm, ruling that the Forest Service had breached the agreement by not supporting the purchase price with an independent, Yellow Book-compliant appraisal. The court rejected the government's defenses of waiver and equitable estoppel and awarded damages to Hahnenkamm.The United States Court of Appeals for the Federal Circuit partially reversed the lower court's decision. The appellate court found that Hahnenkamm could not have reasonably relied on the contractual representation that the appraisal was independent. However, the court remanded the case back to the lower court for further proceedings to determine whether Hahnenkamm reasonably relied on the representation that the appraisal was Yellow Book-compliant. The court also remanded the lower court's rejection of the equitable estoppel defense.On cross-appeal, Hahnenkamm argued that the lower court erred in its damages determination. The appellate court affirmed the lower court's damages determination, finding no abuse of discretion in its analysis. View "HAHNENKAMM, LLC v. US " on Justia Law

The case involves Image API, LLC, a company that provided services to the Texas Health and Human Services Commission (HHSC) from 2009 to 2015. Image's job was to manage a processing center for incoming mail related to Medicaid and other benefits programs. The agreement between the parties stated that HHSC would compensate Image using its “retrospective cost settlement model”. In 2016, HHSC notified Image that an independent external firm would conduct an audit of Image’s performance and billing for the years 2010 and 2011. The audit concluded that HHSC had overpaid Image approximately $440,000 in costs relating to bonuses, holiday pay, overtime, and other unauthorized labor expenses. HHSC then sought to recoup the overpayments by deducting from payments on Image’s invoices.The trial court granted HHSC’s motion for summary judgment and signed a final judgment for the commissioner. The court of appeals reversed the trial court’s judgment and dismissed Image’s entire suit for want of jurisdiction. Image sought review.The Supreme Court of Texas held that Image is a Medicaid contractor under Section 32.0705(a), and that the deadline in Section 32.0705(d) for auditing HHSC’s Medicaid contractors is mandatory. However, the court ruled that HHSC’s failure to meet the deadline does not preclude it from using the result of the audit or pursuing recoupment of overcharges found in the audit. The court affirmed the part of the court of appeals’ judgment dismissing Image’s claims arising from the 2016 audit for lack of jurisdiction, reversed the part of the judgment dismissing the remainder of Image’s suit, and remanded to the trial court for further proceedings. View "IMAGE API, LLC v. YOUNG" on Justia Law

The case revolves around a dispute over a public contract for services to be rendered to the state. The plaintiffs, Talley Amusements, Inc. and others, alleged that the 32nd District Agricultural Association and others violated the Public Contract Code section 10339 when they solicited proposals for a master carnival operator contract for the county fair. The plaintiffs claimed that the request for proposal (RFP) was written in such a way that only one carnival operator in the United States could qualify, thereby limiting the bidding process.The Superior Court of Orange County initially reviewed the case. The court found that section 10339, which prohibits a state agency from drafting an RFP in a way that directly or indirectly limits bidding to any one bidder, did not apply to this particular contract. As a result, the court denied the plaintiffs' request for a temporary injunction under section 10421, which allows a court to issue a temporary injunction preventing further dealings on a public contract awarded in violation of section 10339.The case was then brought before the Court of Appeal of the State of California Fourth Appellate District Division Three. The main issue on appeal was whether the competitive bidding requirements of section 10339 apply to a district agricultural association’s RFP on a master carnival contract. After reviewing the matter de novo, the court held that section 10339 did not apply to the contract at issue because it was not a contract for services to be rendered to the state. Therefore, the court affirmed the trial court’s order denying injunctive relief under section 10421. View "Talley Amusements v. The 32nd District Agricultural Association" on Justia Law

The case involves a dispute between the Florida Division of Emergency Management (the Division) and a private company, Essential Diagnostics, LLC, over a contract for the purchase of COVID-19 test kits. The Division contracted with Essential Diagnostics to buy 200,000 COVID-19 test kits for $2.2 million. However, Essential claimed that the Division ordered 600,000 tests but only paid for 200,000. The Division, on the other hand, insisted that it only ever agreed to buy 200,000 tests and that it paid for them in full. Essential assigned its rights under the contract to Global Integrated Concepts, which sued the Division in Florida state court. However, the state court dismissed the complaint. Subsequently, Global and two other parties involved in the transaction sued the Division in federal district court in North Carolina, seeking to recover the same $4.4 million Global sought as damages in its state court suit.The Division moved to dismiss the suit on the grounds of sovereign immunity. The district court denied the motion to dismiss, concluding that the Division waived its sovereign immunity by contracting with the plaintiffs. The Division appealed this decision.The United States Court of Appeals for the Fourth Circuit vacated the district court’s order and remanded the case for further proceedings. The appellate court found that the district court erred in concluding that the Division waived its sovereign immunity by contracting with the plaintiffs. The court clarified that the rules governing waiver of federal-law sovereign immunity in federal court come from federal law, not state law. The court concluded that the district court failed to distinguish between the defenses and immunities a State might enjoy under state law and the constitutionally protected sovereign immunity that States enjoy from suit in federal court. The court also rejected the plaintiffs' argument that the court lacked jurisdiction over the appeal. View "Global Innovative Concepts, LLC v. State of Florida, Division of Emergency Management" on Justia Law

The Supreme Court of the State of Colorado was asked to review a case involving a dispute between the City of Aspen and the Burlingame Ranch II Condominium Owners Association, Inc. The dispute centered around alleged construction defects in an affordable housing project overseen by the City of Aspen. The Association claimed that Aspen had breached express and implied warranties, and Aspen argued that the claims were barred by the Colorado Governmental Immunity Act (CGIA), which provides immunity to public entities from claims for injury that lie in tort or could lie in tort.The lower court agreed with Aspen, ruling that the Association's claims sounded in tort, or could sound in tort, and were thus barred by the CGIA. The Association appealed, and the Colorado Court of Appeals reversed the lower court's decision. The appellate court reasoned that the Association's claims could only sound in contract, and thus were not barred by the CGIA. The court relied on the economic loss rule, which generally provides that a party suffering only economic loss from the breach of a contractual duty may not assert a tort claim for such a breach absent an independent duty of care under tort law.The Supreme Court of the State of Colorado reversed the appellate court's decision. The court held that the economic loss rule has no bearing on whether the CGIA bars a plaintiff’s claims. The court clarified that the CGIA bars claims that could arise in both tort and contract, and that the economic loss rule cannot rescue an otherwise CGIA-barred claim. The case was remanded back to the lower court for further proceedings. View "City of Aspen v. Burlingame Ranch II" on Justia Law

Percipient.ai, Inc., a company that offers a commercial computer vision (CV) platform, appealed a decision by the United States Court of Federal Claims that dismissed its case against the United States and CACI, Inc.-Federal. The case centered on the National Geospatial-Intelligence Agency's (NGA) procurement process for its SAFFIRE project, which aimed to improve its processes for obtaining and storing visual intelligence data. Percipient alleged that NGA and its contractor, CACI, violated the Federal Acquisition Streamlining Act of 1994 (FASA) and other procurement-related statutes by not considering its commercial CV platform, Mirage, for the project.The Court of Federal Claims had dismissed Percipient's case, ruling that it lacked subject matter jurisdiction under the FASA task order bar, which limits protests related to the issuance of task orders. The court also rejected Percipient's arguments related to the Tucker Act, standing, and timeliness.The United States Court of Appeals for the Federal Circuit reversed the lower court's decision. It held that the FASA task order bar did not apply because Percipient's protest was not connected to the issuance of a task order. The court also found that Percipient's protest fell within the jurisdiction of the Court of Federal Claims under the Tucker Act, as it alleged a violation of procurement-related statutes. The court further held that Percipient had standing to bring the case and that its claims were timely. The case was remanded for further proceedings. View "PERCIPIENT.AI, INC. v. US " 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

Eghbal Saffarinia, a former high-ranking official in the Department of Housing and Urban Development’s Office of the Inspector General (HUD-OIG), was required by federal law to file annual financial disclosure forms detailing most of his financial liabilities over $10,000. One of Saffarinia’s responsibilities was the allocation of HUD-OIG’s information technology contracts. An investigation revealed that Saffarinia had repeatedly falsified his financial disclosure forms and failed to disclose financial liabilities over $10,000. The investigation also revealed that one of the persons from whom Saffarinia had borrowed money was the owner of an IT company that had been awarded HUD-OIG IT contracts during the time when Saffarinia had near-complete power over the agency operation.Saffarinia was indicted on seven counts, including three counts of obstruction of justice. A jury convicted Saffarinia on all seven counts, and the District Court sentenced him to a year and a day in federal prison, followed by one year of supervised release. Saffarinia appealed his conviction, arguing that the law under which he was convicted did not extend to alleged obstruction of an agency’s review of financial disclosure forms because the review of these forms is insufficiently formal to fall within the law’s ambit. He also argued that the evidence presented at trial diverged from the charges contained in the indictment, resulting in either the constructive amendment of the indictment against him or, in the alternative, a prejudicial variance. Finally, Saffarinia challenged the sufficiency of the evidence presented against him at trial.The United States Court of Appeals for the District of Columbia Circuit found no basis to overturn Saffarinia’s conviction. The court held that the law under which Saffarinia was convicted was intended to capture the sorts of activity with which Saffarinia was charged. The court also found that the government neither constructively amended Saffarinia’s indictment nor prejudicially varied the charges against him. Finally, the court found that the evidence presented at Saffarinia’s trial was sufficient to support his conviction. The court therefore affirmed the judgment of the District Court. View "USA v. Saffarinia" on Justia Law

The case involves Montalla, LLC ("Montalla") and the Commonwealth of Virginia, Department of Transportation ("VDOT"), and the Comptroller of Virginia (collectively the "Commonwealth"). Montalla filed a five-count complaint against the Commonwealth related to several contracts VDOT had entered into for construction inspection services. The circuit court dismissed the entire complaint, ruling that sovereign immunity barred all five counts. The Court of Appeals affirmed the judgment of the circuit court, concluding that Counts I-III of the complaint were barred by sovereign immunity and that Counts IV-V were barred by the entry of a settlement agreement entered into by the pertinent parties.The Court of Appeals of Virginia affirmed the lower court's decision, concluding that the first three counts of the complaint were barred by sovereign immunity and that the last two counts were barred by the entry of a settlement agreement. The Court of Appeals reasoned that the settlement agreement was enforceable and that Montalla had not sufficiently alleged duress or repudiation to set it aside.The Supreme Court of Virginia reversed the judgment of the Court of Appeals. The Supreme Court held that the doctrine of sovereign immunity did not bar Montalla's claims based on valid contracts. The Court also held that the Court of Appeals erred in concluding that the settlement agreement, including the release of claims contained therein, was enforceable at this stage of the proceedings. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Montalla, LLC v. Commonwealth" on Justia Law

The case involves a dispute between Missoula County and the Montana Department of Corrections (DOC) over the reimbursement rate for housing DOC inmates in county detention centers. The County and the DOC had entered into a contract in 2015, setting a reimbursement rate of $88.73 per day for each inmate. However, in 2015, the Montana Legislature capped the reimbursement rate at $69 per day. The County filed a lawsuit in 2020, alleging breach of contract, breach of the implied covenant of good faith and fair dealing, and unjust enrichment.The District Court granted summary judgment to the DOC, concluding that the County's contract claims were time-barred by a one-year statute of limitations. It also found that the County's tort claim for breach of the covenant of good faith was not supported by a special relationship and that the County could not recover under a theory of unjust enrichment.The Supreme Court of Montana affirmed the District Court's decision. It held that the one-year statute of limitations applied to the County's contract claims, rejecting the County's argument that an eight-year limitation period should apply. The court also agreed with the lower court that the County's tort claim for breach of the covenant of good faith was not supported by a special relationship. Finally, the court concluded that the County could not recover under a theory of unjust enrichment, as the County had not demonstrated that the DOC had reaped an inequitable gain. View "Missoula County v. Department of Corrections" on Justia Law