Justia Contracts Opinion Summaries

Dennis Hagenow was injured in an automobile accident with Betty Schmidt. Hagenow and his wife (Plaintiffs) filed an uninsured motorist claim with American Family Mutual Insurance Company. American Family denied the claim, determining that Schmidt’s vehicle was not an uninsured motor vehicle under Plaintiffs’ policy. Plaintiffs subsequently filed a breach of contract action against American Family. American Family moved for summary judgment, arguing (1) because Schmidt had automobile insurance at the time of the collision, she was not an uninsured motorist (UM) under the policy; and (2) Plaintiffs were not “legally entitled to recover” under the policy because a jury in Plaintiffs’ underlying action against Schmidt found Schmidt not liable for Plaintiffs’ damages. The district court denied the motion. The Supreme Court reversed, holding (1) Plaintiffs were not “legally entitled to recover” under Iowa law or their UM policy; and (2) Schmidt’s vehicle was not an uninsured motor vehicle under the terms of Plaintiffs’ UM provision. Remanded. View "Hagenow v. Am. Family Mut. Ins. Co." on Justia Law

Plaintiff formed a contract with Imperial Premium Finance with regard to a financing arrangement for life insurance. Imperial later assigned its interest in the arrangement to Defendant, a limited partnership with its principal place of business in California. Plaintiff filed a petition for declaratory judgment in Iowa, claiming that the contract was not valid. The district court granted Defendant’s motion to dismiss for lack of personal jurisdiction, concluding that that contacts of Imperial, the assignor, did not impute to Defendant, the assignee. The Supreme Court reversed, holding (1) an assignor’s contacts with Iowa are not automatically imputed to the assignee for purposes of obtaining personal jurisdiction over the assignee, but this assignee is subject to personal jurisdiction in Iowa based on its own contacts with this forum through the contractual relationships it assumed by the assignment; and (2) Defendant in this case did have the required minimum contacts to subject Defendant to personal jurisdiction in Iowa. Remanded. View "Ostrem v. PrideCo Secure Loan Fund, LP" on Justia Law

Plaintiff was a passenger who was injured while riding in the vehicle of his brother, who had coverage, including underinsured motorist (UIM) coverage, with Defendant. The policy contained a provision limiting the time to file an action to recover UIM benefits. Plaintiff brought this action to recover UIM benefits approximately one month after the deadline set forth in the policy. Defendant moved for summary judgment, claiming Plaintiff’s petition was untimely because he failed to file it within the policy’s two-year deadline. The district court denied the motion. The Supreme Court reversed, holding (1) Plaintiff, as an insured and a third-party beneficiary of the policy, did not have greater rights than the policyholder, and therefore, Plaintiff could not avoid the contractual time limitation unless the policyholder under similar circumstances would have been able to avoid it; and (2) the record did not demonstrate either that the policy’s time limit was unreasonable or that Defendant should be equitably estopped from enforcing it. Remanded for entry of summary judgment in favor of Defendant. View "Osmic v. Nationwide Agribusiness Ins. Co." on Justia Law

Lender loaned Borrowers $52,000 pursuant to a loan agreement (agreement) and promissory note ( note). After Borrowers stopped making payments on the loan, Lender filed a petition to collect the total principal due on the agreement and note. The trial judge determined (1) Lender did not meet its burden to prove a breach of contract on the agreement and note because it did not show evidence of the terms of the agreement and repayment schedule, and (2) even if there was an enforceable contract, Lender failed to prove damages. The Supreme Court reversed, holding (1) the record established as a matter of law that Lender proved the existence of a contract based upon the agreement and note; and (2) the district court applied the wrong burden of proof to determine a breach and the amount of damages owed, if any, on the agreement and note. Remanded. View "Iowa Mortgage Ctr., LLC v. Baccam" on Justia Law

John Corrado and his company (collectively, Corrado) and Life Investors Insurance Company of America (LICA) entered into a settlement agreement following a dispute. The agreement purported to bear Corrado's signature, but Corrado challenged the signatures' validity. The U.S. district court granted summary judgment to LICA, concluding that Corrado ratified the parties' contract. The U.S. court of appeals reversed. On remand, the district court found the settlement agreement authenticated. The Iowa Supreme Court answered a certified question of law by holding that if a party receives a copy of an executed contract with that party's signature thereon, even where it is not known who applied the party's signature to the contract or whether the signature was authorized, and the party does not challenge the signature or otherwise object to the contract and accepts benefits and obligations under the contract for at least six years, then the party has ratified the contract and is therefore bound by its terms. View "Life Investors Ins. Co. of Am. v. Estate of Corrado" on Justia Law

A husband and wife applied for life insurance policies from Farm Bureau Life Insurance Company and later sued Farm Bureau for its alleged negligence in failing to notify them of their HIV-positive status. Farm Bureau settled the negligence claims, sued its insurers for indemnity, and sued its insurance broker for breach of contract and negligence in failing to provide timely notice to the insurers. The district court granted summary judgment (1) in favor of the insurers on the ground that Farm Bureau had failed to give them timely notice of the applicants' liability claims, and (2) in favor of the broker after concluding that even if the insurers had been given timely notice of the applicants' tort claims against Farm Bureau, coverage for those claims would have been precluded under two separate exclusions. In this appeal, Farm Bureau challenged the judgment in favor of the broker. The Supreme Court affirmed, holding that the underwriting exclusion would have precluded coverage for the applicants' claims even if the insurers had been timely notified under the policy's notice requirement. View "Farm Bureau Life Ins. Co. v. Holmes Murphy & Assocs., Inc." on Justia Law

Chartis Insurance issued two workers' compensation insurance policies to Action Warehouse Company. Action, in turn, contracted with two tire companies to provide employees to operate tire warehouses owned by the companies and used exclusively to store the goods manufactured by the respective employers. Originally, Chartis classified the Action employees who staffed the warehouses under the National Council on Compensation Insurance (NCCI) classification code applicable to general warehouse employees. Later, Chartis retroactively and prospectively changed the employees' classification code to the code applicable to rubber tire manufacturing, resulting in a significantly higher premium. Action appealed. The NCCI Iowa workers' compensation appeals board ruled in favor of Chartis. The Iowa Insurance Commissioner reversed, and the district court affirmed. At issue before the Supreme Court was whether the Commissioner had the authority under Iowa Code 515A.1 to consider an as-applied challenge to a workers' compensation liability insurance rating schedule approved for use in accordance with Iowa law. The Supreme Court reversed, holding that the Commissioner did not have the authority to determine that a specific application of a plan approved under Iowa Code 515A.4 violated the statute's general purpose as outlined in section 515A.1 by being excessive, inadequate, or unfairly discriminatory. View "Chartis Ins. v. Iowa Ins. Comm'r" on Justia Law

Plaintiff and Defendant were brother and sister. Defendant was a longtime resident of Maryland. Plaintiff allegedly lived in Iowa in 2003. After Plaintiff obtained employment in Iraq in 2003, he opened a checking account in Des Moines and provided Defendant with checks that could be used to draw on the account to provide for the needs of his children and to pay the bills. Instead of using the checks as agreed, Plaintiff claimed Defendant used the checks to withdraw funds for her personal use. Plaintiff filed a lawsuit against Defendant in Iowa district court for breach of contract, conversion, bad faith, fraud, and breach of fiduciary duty. The district court dismissed the complaint for lack of personal jurisdiction over Defendant, finding that sufficient minimum contacts were lacking. The Supreme Court reversed, holding that Defendant was subject to personal jurisdiction in Iowa under the Calder v. Jones foreseeable effects test based on the claim of an intentional tort in Iowa. Remanded. View "Shams v. Hassan" on Justia Law

Steven Sheeder and Barlett Grain Co. entered into oral agreements for the sale of grain. The parties later confirmed the agreement with a signed, written document containing an arbitration clause that was not part of the oral agreements. After Bartlett requested adequate assurance of performance and Sheeder did not provide such assurance, thus repudiating the contracts, Bartlett filed a complaint against Sheeder with the National Grain Feed Association (NGFA). Sheeder failed to sign an arbitration contract as required by NGFA arbitration rules, and NGFA entered a default judgment for Bartlett for breach of contract. Bartlett subsequently filed an application for confirmation of the arbitration award. The district court denied the application, concluding that there was no enforceable agreement between the parties to arbitrate. The Supreme Court reversed, holding (1) Bartlett and Sheeder entered into written agreements to arbitrate because the parties' oral agreements were modified by signed writings including agreements to arbitrate; and (2) the written agreements between Sheeder and Bartlett were not unconscionable. View "Barlett Grain Co. v. Sheeder" on Justia Law

Plaintiffs, farmers, purchased a Farm-Guard insurance policy from First Maxfield Mutual Insurance Association. Grinnell Mutual Reinsurance Company (Grinnell Mutual) reinsured the policy. Two years later, 535 of the hogs Plaintiffs were raising suffocated to death in Plaintiffs' building. Plaintiffs filed a claim with Grinnell Mutual to recover under the policy, but Grinnell Mutual denied the claim. Plaintiffs sued Grinnell Mutual for breach of contract. Both parties filed motions for summary judgment. The district court denied Grinnell Mutual's motion and granted Plaintiffs' motion based on the reasonable expectation doctrine. The court of appeals affirmed on alternative grounds, concluding the insurance policy was ambiguous and construing the ambiguity in favor of Plaintiffs. The Supreme Court reversed, holding (1) the policy was not ambiguous, and as a matter of law, the policy did not provide coverage; and (2) as a matter of law, the doctrine of reasonable expectations did not apply here. Remanded with instructions to enter judgment in favor of Grinnell Mutual. View "Boelman v. Grinnell Mut. Reinsurance Co." on Justia Law