Justia Contracts Opinion Summaries

The Northwest Arkansas Conservation Authority is a public corporation created to handle wastewater treatment for municipalities in northwest Arkansas. After a series of pipeline failures, the Authority sued the pipeline contractor and its surety, alleging deficient construction. The Authority sued outside the time periods specified in the relevant statutes of limitations and repose, but asserted that the time did not run against its claims, because the Authority was suing as a public entity seeking to vindicate public rights. The district court concluded that the rights the Authority sought to enforce were merely proprietary and that its claims were therefore time-barred.   The Eighth Circuit affirmed. The court explained that the relevant proprietary interests are not transformed into public rights just because the Authority spent public money to repair the pipeline. Every action by a public entity impacts the public fisc to some degree. But if financial implications alone were enough to invoke nullum tempus, then the public-rights exception would swallow the general rule that statutes of limitations and repose run against municipal entities. Here, the damages sought would replenish the public entity’s coffers, but the relief would not vindicate a distinct public right. The Authority therefore cannot invoke nullum tempus to avoid the statutes of limitations or repose. View "NW AR Conservation Authority v. Crossland Heavy Contractors" on Justia Law

The U.S. Department of Housing and Urban Development (HUD) oversees the Section 8 low-income housing assistance program, 42 U.S.C. 1437f. New Lansing renewed its Section 8 contract with Columbus Metropolitan Housing Authority in 2014 for a 20-year term. In 2019, at the contractual time for its fifth-year rent adjustment, New Lansing submitted a rent comparability study (RCS) to assist CM Authority in determining the new contract rents. Following the 2017 HUD Section 8 Guidebook, CM Authority forwarded New Lansing’s RCS to HUD, which obtained an independent RCS. Based on the independent RCS undertaken pursuant to HUD’s Guidebook requirements, the Housing Authority lowered New Lansing’s contract rents amount.The Sixth Circuit affirmed the dismissal of New Lansing’s suit for breach of contract. The Renewal Contract requires only that the Housing Authority “make any adjustments in the monthly contract rents, as reasonably determined by the contract administrator in accordance with HUD requirements, necessary to set the contract rents for all unit sizes at comparable market rents.” HUD has authority to prescribe how to determine comparable market rents, the Renewal Contract adopted those requirements, and thus the Housing Authority was required to follow those HUD methods. The Housing Authority did not act unreasonably by following the requirements in the 2017 HUD guidance. View "New Lansing Gardens Housing Limited Partnership v. Columbus Metropolitan Housing Authority" on Justia Law

The Supreme Court held that the Town of Weddington was protected from Providence Volunteer Fire Department, Inc.'s fraud-related claims based upon the doctrine of governmental immunity and that Mayor Deter was protected from those claims based upon the doctrine of legislative immunity, and therefore, the trial court erred by failing to dismiss Providence's fraud-related claims.The Town entered into three contracts with Providence in order to procure fire protection services for its residents, renovate its fire station, and purchase and lease the fire station back to Providence. Substantial improvements were subsequently made to Providence's fire station, and the Town then obtained a quitclaim deed to the property. Thereafter, the Town voted to terminate the lease with Providence. Providence filed a complaint asserting various forms of relief. The trial court denied the Town's motion to dismiss. The court of appeals reversed, ruling that Providence's fraud-related claims were barred by governmental and legislative immunity. The Supreme Court affirmed, holding that the court of appeals did not err in deciding that (1) the Town was shielded from Providence's fraud-related claims on the basis of governmental immunity; and (2) Mayor Deter was shielded from Providence's fraud-related claims on the basis of legislative immunity. View "Providence Volunteer Fire Department, Inc. v. Town of Weddington" on Justia Law

The Seventh Circuit affirmed the judgment of the district court granting the State's motion to dismiss this action brought by two Illinois counties challenging the 2021 passage of a law prohibiting State agencies and political subdivisions from contracting with the federal government to house immigration detainees, holding that the district court properly dismissed the action for failure to state a claim.In their complaint, Plaintiffs argued that the law at issue was invalid under principles of both both field and conflict preemption and that it violated the doctrine of intergovernmental immunity. The district denied relief. The Seventh Circuit affirmed, holding (1) because it was not preempted by federal immigration statutes the law was not invalid as a matter of field or conflict preemption; and (2) the law did not violate principles of intergovernmental immunity. View "McHenry County v. Raoul" on Justia Law

The Supreme Court reversed the order of the district court granting summary judgment in favor of the cities of Pella and Oskaloosa regarding the validity of an agreement between the cities and Mahaska County to establish a regional airport authority, holding that Landowners had standing to challenge the agreement.Landowners brought this action seeking a judgment that the agreement at issue was illegal and an injunction to prevent the transaction. The district court held that Landowners lacked standing to bring the suit and granted summary judgment in favor of the Cities. The Supreme Court reversed, holding (1) by entering into the agreement, the County's Board of Supervisors bound future board to a particular course of legislative action, in violation of the Iowa Constitution; (2) the agreement violated precedent regarding delegation of a municipality's legislative power; and (3) therefore, the district court erred in declaring the agreement to be valid and ordering specific performance by the County of its obligations under the agreement. View "Site A Landowners v. South Central Regional Airport Agency" on Justia Law

Central Coast Development Company (“Central Coast”) owns a parcel of property within the City of Pismo Beach (“City”). The City approved Central Coast's application for a development permit. The City and Central Coast applied to the San Luis Obispo Local Agency Formation Commission (LAFCO) to annex the property. LAFCO denied the annexation application. The Special District Risk Management Authority ("SDRMA"), a public entity self-insurance pool, paid for LAFCO's fees and costs. The City sued Central Coast to recover fees and costs expended in the Central Coast action against LAFCO. LAFCO and SDRMA cross-complained against the City and Central Coast for fees and costs. The trial court granted the City and Central Coast’s judgment on the pleadings against LAFCO and SDRMA (collectively LAFCO). The court denied LAFCO's request for leave to amend its pleadings. LAFCO appealed.The Second Appellate Division affirmed and while the appeal in LAFCO I was pending, the City and Central Coast moved for attorney fees based on section 1717. The trial court granted the motion. The court awarded $172,850 to the City and $428,864 to Central Coast. LAFCO again appealed (“LAFCO II).”The court reversed the judgment order finding that section 1717 cannot apply because it is beyond LAFCO’s powers to bind itself or an applicant to the attorney fee agreement at issue. The lack of such authority renders the contract unenforceable against LAFCO. Further, Central Coast may not recover fees for the same reason that LAFCO could not recover fees. View "San Luis Obispo Local etc. v. Central Coast etc." on Justia Law

Hospitals provided emergency medical services to members of the county’s health plan, which is licensed and regulated by the state Department of Managed Health Care under the Knox-Keene Health Care Service Plan Act, Health & Saf. Code 1340. The county reimbursed the Hospitals for $28,500 of a claimed $144,000. The Hospitals sued, alleging breach of an implied-in-fact or implied-in-law contract. The trial court rejected the county’s argument that it is immune from the Hospitals’ suit under the Government Claims Act (Gov. Code 810).The court of appeal reversed. The county is immune from common law claims under the Government Claims Act and the Hospitals did not state a claim for breach of an implied-in-fact contract. The county does not contest its obligation to reimburse the Hospitals for the reasonable and customary value of the services; the issue is what remedies may be pursued against the county when the reasonableness of the reimbursement is disputed. The Knox-Keene Act provides alternative mechanisms to challenge the amount of emergency medical services reimbursements. A health care service plan has greater remedies against a private health care service plan than it does against a public entity health care service plan, a result driven by the Legislature broadly immunizing public entities from common law claims and electing not to abrogate that immunity in this context. View "County of Santa Clara v. Superior Court" on Justia Law

CSI was awarded a government contract to provide “[a]ir charter services operated by brokers, and various auxiliary services that will be used to support the contract.” After U.S. Immigration and Customs Enforcement (ICE) canceled various removal flights, CSI sought payment ($40,284,548.89) from the Department of Homeland Security. The Civilian Board of Contract Appeals dismissed the action, concluding that the CSI Terms and Conditions, which include “Cancellation Charges” were not incorporated by reference into the Schedule Contract.The Federal Circuit vacated and remanded. The Schedule Contract expressly incorporates at least one document that unambiguously identifies the CSI Terms and Conditions and makes clear such terms and conditions apply to all operations. CSI’s Offer plainly identified the CSI Terms and Conditions—along with the CSI Commercial Sales Practice attachment, its Pricing Policy, and its Commercial Price List—in the “Pricing” section of its table of contents. View "CSI Aviation, Inc. v. Department of Homeland Security" on Justia Law

Employees of a Navy services contractor, SA-TECH, sued the contractor in California state court for violations of the state’s labor laws. Before and during that suit, SA-TECH sought guidance from the Navy as to whether California’s labor laws applied to it and its subcontractors, given the federal nature of its service contract. Those requests went unanswered. SA-TECH’s claim with its contracting officer under the Contract Disputes Act was denied. SA-TECH then sought declaratory relief on the questions: whether the modified understanding of California labor laws would control SA-TECH’s operations on Navy and Navy-chartered ships; whether SA-TECH would be permitted or required by the Navy, under its contracts, to pay any sleep-time over-time; and whether costs incurred by SA-TECH in settling the state-court litigation would be allowable costs under its current contract.The district court dismissed the complaint, citing lack of subject matter jurisdiction pursuant to the Contract Disputes Act’s exhaustion requirements, 41 U.S.C. 7103(a)(1)–(3). The Fourth Circuit affirmed. SA-TECH did not specifically assert any legal or contractual grounds entitling it to the Navy’s opinion on its agency status. Its other issues are monetary claims for which SA-TECH did not present a requested sum certain, as required to exhaust its remedies. View "Systems Application & Technologies, Inc. v. United States" on Justia Law

Southern Power and Cleveland County, North Carolina executed an “Incentive Development Agreement” in July 2007, providing that if Southern built and operated a natural gas plant — a decision left to Southern’s sole discretion — the county would make substantial cash payments to Southern. The North Carolina legislature enacted a new law (Subsection H) 37 days later, imposing more stringent requirements on such agreements, including a mandate that they include a recapture provision allowing a municipality to recover cash incentives already paid if the private entity breaches the agreement. In November-December 2008, Southern secured contracts to supply utility companies with electricity produced at the plant. Southern then asked the county to reaffirm its commitment to the Agreement. Cleveland County adopted a resolution at its January 6, 2009, meeting stating that it was committed to the incentive grants. Southern broke ground on the plant in October 2009 and began commercial operations in December 2012. Cleveland County, however, refused to pay Southern any cash incentives, arguing that the Agreement failed to comply with Subsection H.The district court dismissed the case as barred by North Carolina governmental immunity. The Fourth Circuit affirmed. Cleveland county never waived its governmental immunity from suit. View "Southern Power Co. v. Cleveland County" on Justia Law