Justia Contracts Opinion Summaries

Benchmark Property Remodeling, LLC, a construction company, performed remodeling work on a building owned by Grandmothers, Inc., which was leased to the Kansas Department of Revenue (KDOR). The work was based on quotes finalized between KDOR and Benchmark, and a "Third Amendment to Lease" between KDOR and Grandmothers. Benchmark completed the work and invoiced Grandmothers and KDOR. KDOR paid Grandmothers, but Grandmothers only partially paid Benchmark, withholding some amounts for various reasons. Benchmark sued Grandmothers, KDOR, and others for breach of contract, unjust enrichment, and other claims.The Shawnee District Court granted partial summary judgment in favor of Grandmothers on several claims, concluding there was insufficient evidence of a contract between Benchmark and Grandmothers. The court also granted KDOR's motion for judgment on the pleadings. Benchmark then dismissed its remaining claims without prejudice and appealed the partial summary judgment and judgment on the pleadings.The Kansas Court of Appeals reviewed the case and concluded that appellate jurisdiction was proper because Benchmark did not refile its dismissed claims, making the district court's judgment final. The panel reversed the district court's entry of judgment on the pleadings for KDOR, noting significant factual issues regarding the parties' intent. The panel also reversed the district court's summary judgment for Grandmothers, finding that the evidence could support a finding of a contract between Benchmark and Grandmothers.The Kansas Supreme Court affirmed the Court of Appeals' decision, holding that the district court's partial summary judgment became final with the dismissal of the remaining claims, thus granting appellate jurisdiction. The Supreme Court agreed that there were genuine disputes of material fact regarding the existence of a contract, making summary judgment inappropriate. The case was remanded to the district court for further proceedings. View "Benchmark Property Remodeling v. Grandmothers, Inc." on Justia Law

The case revolves around a dispute over the ownership of a purebred show dog named Oscar. The parties involved are Oscar's breeder, Elizabeth "Betsy" Shauck, and Dave Jennings and Emily McLeod, who have raised Oscar since he was a puppy. Dave and Emily filed a petition to quiet title to Oscar against Betsy, who counterclaimed for breach of contract, replevin, conversion, for a restraining order and preliminary injunction, and to quiet title. Betsy's preliminary injunction counterclaim asked the district court to prevent Dave and Emily from harboring Oscar and to order his immediate return to her.The district court held a three-day hearing, which was supposed to be on Betsy's request for a preliminary injunction. However, the court expanded the scope of the hearing and made findings of fact and conclusions of law on the merits of all issues pending in the underlying lawsuit, including Oscar's ownership, contract disputes, and damages. Dave and Emily appealed this decision, arguing that the district court denied their due process rights by deciding the case on the merits when it had only set the hearing on Betsy's preliminary injunction.The Kansas Court of Appeals panel held that the district court violated Dave and Emily's due process rights by expanding the scope of the hearing without notice. However, instead of remanding the case, the panel analyzed the parties' ownership interests in Oscar and held that Dave and Betsy co-owned Oscar. Betsy then petitioned the Supreme Court of the State of Kansas for review.The Supreme Court of the State of Kansas affirmed in part and reversed in part the decision of the panel. The court agreed with the panel that the district court erred by expanding the scope of the hearing on Betsy's request for a preliminary injunction. The court found that the district court's decision to consolidate the hearing on Betsy's request for a preliminary injunction with a trial on the case's merits without informing the parties was a denial of due process and an error of law. The court also agreed with the panel's conclusion that the district court's failure prejudiced Dave and Emily. However, the court held that the panel erred by addressing the case's merits after correctly concluding that the district court erred. The court reversed the judgment of the district court and remanded the case for further proceedings. View "Jennings v. Shauck" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing this lawsuit after its prior decision that a 2006 agreement between the cities of Spring Hill and Olathe was unenforceable as a governmental action that could not bind subsequent city councils, holding that Olathe was not entitled to relief on any of its claims of error.The agreement at issue restricted the cities' future growth by establishing boundaries for annexing land lying adjacent to the two cities. The agreement had no fixed expiration term and stated that termination could occur only upon mutual consent of the parties. In 2021, Olathe filed a petition seeking preliminary and injunctive relief to restrain Spring Hill from annexing certain disputed property. The district court denied the request for injunctive relief and then dismissed the suit. The Supreme Court affirmed, holding that the agreement was an unenforceable attempt to bind future city councils to a governmental policy decision. View "City of Olathe v. City of Spring Hill" on Justia Law

In this case about the enforceability about a mortgage clause the Supreme Court affirmed the decision of the court of appeals reversing the decision of the district court dismissing this action, holding that any language in the mortgage agreement between the mortgagor and mortgagee that would give the mortgagee the ability to take possession of the property was unenforceable in light of the Supreme Court's historical interpretation of Kan. Stat. Ann. 58-2301.The mortgage clause at issue granted to the mortgagee/lender the right to immediate and exclusive possession of the mortgaged property upon the event of the mortgagor/borrower's default. In reliance on the clause the mortgagee took possession of the property and filed a foreclosure action. The district court granted judgment in favor of the mortgagee. The mortgagor filed suit, asserting that, before the court order authorized the mortgagee's possession of the property, the mortgagee's possession was wrongful. The district court dismissed the action on the basis of the mortgage remedies provision and the mortgagor's default. The court of appeals reversed, concluding that the mortgagee's reliance on the provisions of executory agreements was unsupported by Kansas law. The Supreme Court affirmed, holding that there was no support in state law for the mortgagee's reliance on the provisions of the executory agreements. View "Fairfax Portfolio LLC v. Carojoto LLC" on Justia Law

The Supreme Court reversed the decision of the court of appeals concluding that the district court committed harmless error in failing to suppress a blood test result, holding that the court of appeals erred when it concluded that Defendant could be guilty of an alternative charge.Following a bench trial on stipulated facts, the district court convicted Defendant of driving with a blood alcohol content of more than 0.08 as measured within three hours of driving. The court of appeals affirmed, holding that, even though the district court should have suppressed the blood test result, the stipulation included facts that supported a conviction on an alternative charge that was not a part of the district court's judgment. The Supreme Court reversed, holding that the court of appeals erred by not considering and applying the conditions that limited the binding nature of the parties' stipulation. View "State v. Braun" on Justia Law

The Supreme Court affirmed the judgment of the district court denying GFTLenexa, LLC relief in an action based on contractual relationships but brought as an inverse condemnation proceeding, holding that there was no error in the reasoning or conclusions of the district court.GFTLenexa, LLC alleged in this action that a condemnation through an eminent domain action resulted in GFTLenexa's intangible property rights being damaged. The action was predicated on its reduced rental income because of an action that it lost to its sublessee involving the condemnation. The district court denied summary judgment to GFTLenexa. The Supreme Court affirmed, holding the proper venue for GFTLenexa to assert its rights was in the eminent domain proceeding, even if it could not have successfully asserted them there because it surrendered its rights through its contractual obligations. View "GFTLenexa, LLC v. City of Lenexa" on Justia Law

The Supreme Court affirmed in part and reversed in part the court of appeals' judgment reversing the district court's judgment dismissing Plaintiffs' claim for, inter alia, product liability, holding that the Kansas Product Liability Act, Kan. Stat. Ann. 60-3301 et seq., does not subsume or extinguish any legally viable alternative cause of action seeking recovery for direct or consequential economic loss.After Plaintiffs built thousands of homes they installed bathroom ceiling fans constructed by Defendants. Several ceiling fans caught fire and damaged several homes. Plaintiffs removed and replaced the remaining fans and then brought this lawsuit asserting several claims, including claims for product liability. The district court concluded that the economic loss doctrine barred Plaintiffs from recovery. The court of appeals reversed, holding that the economic loss doctrine did not bar Plaintiffs from asserting a product liability claim because the property damage to the homes was not economic loss. The Supreme Court reversed in part, holding (1) the court of appeals properly reversed the summary judgment with respect to any property damage; and (2) because it cannot be discerned whether some or all of the claims Plaintiffs claimed as removal and replacement damages were legally recoverable in an unjust enrichment cause of action, the case must be remanded. View "Corvias Military Living, LLC v. Ventamatic, Ltd." on Justia Law

In this employment case arising out of the sale of a cattle feedlot the Supreme Court affirmed the decision of the court of appeals reversing summary judgment on Plaintiff's implied-in-fact employment contract claim and Plaintiff's claim for promissory estoppel, holding that a genuine issue of material fact existed preventing summary judgment.Plaintiff moved his employment from the old owner of the feedlot to the new owner, Defendant. Because of operational changes, Defendant later terminated Plaintiff's employment. Plaintiff then sued Defendant alleging breach of an employment contract, or in the alternative, detrimental reliance and estoppel. The district court concluded that Plaintiff was Defendant's employee at will, and therefore, Defendant could terminate Plaintiff's employment at any time without cause. The court of appeals reversed, holding that whether Plaintiff's employment was at will - or protected by an implied-in-fact contract - was a disputed question of fact. The Supreme Court affirmed, holding (1) whether a meeting of minds existed between the parties on an implied-in-fact employment contract presented a genuine issue of material fact precluding summary judgment; and (2) therefore, summary judgment should not have been granted for Defendant on Plaintiff's promissory estoppel claim. View "Peters v. Deseret Cattle Feeders, LLC" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the district court’s garnishment order in favor of a judgment creditor and her insurer, holding that the insurer demonstrated prejudice as a matter of law from its lack of notice of suit.The policy in this case contained a requirement that the insured inform the insurer of a lawsuit arising out of an otherwise covered automobile accident. After the judgment creditor and her insurer obtained the garnishment order, the court of appeals affirmed. The Supreme Court reversed, holding that the stipulated facts established that the insured breached his notice-of-suit duty under the insurance policy and that the insurer was prejudiced by that breach. View "Geer v. Eby" on Justia Law

The Supreme Court reversed the decision of the Court of Appeals affirming the decision of the district court granting summary judgment to The Bar Plan Mutual Insurance Company on Daniel Becker’s insurance coverage dispute with the company, holding that the lower courts erroneously relied upon certain caselaw in granting summary judgment and that, under the correct caselaw, questions of fact remained that were inappropriate for summary judgment.Specifically, the Court held (1) the lower courts erred in relying on the “expansion of coverage” rule in concluding that Becker was asking for the coverage to be expanded beyond the insurance contract’s terms and that that courts should instead have continued their analysis to see if estoppel was appropriate to apply to the facts under the “reservation of rights” rule; and (2) because several genuine issues of material fact remained on the issue of estoppel, this case must be remanded for further proceedings. View "Becker v. Bar Plan Mutual Insurance Co." on Justia Law