Justia Contracts Opinion Summaries

Articles Posted in Labor & Employment Law
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Paulo Trindade, a former employee of Grove Services, Inc., sued his previous employer for breach of contract and violations of the Massachusetts Wage Act, claiming he had been underpaid on his sales commission compensation for the years 2014, 2015, and 2016. Following a bench trial, the United States District Court for the District of Massachusetts ruled in part for Trindade and in part for Grove, awarding Trindade $330,597 in damages. Both parties appealed. The United States Court of Appeals for the First Circuit affirmed the lower court's judgment. The Court of Appeals agreed with the district court's conclusion that Trindade's amended complaint, which included a claim for unpaid wages for 2016, related back to his original complaint, making the claim timely under Massachusetts law. The Court of Appeals also concluded that the district court was correct in its decision to award the damages it did, including an amount for the late payment and underpayment of Trindade's 2016 commission. View "Trindade v. Grove Services, Inc." on Justia Law

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In the case before the Supreme Court of Alabama, David and Anna Roberson appealed from an order by the Jefferson Circuit Court that dismissed their indemnification claim against Drummond Company, Inc. ("Drummond"). David, a former vice president of Drummond, was convicted of bribery in federal court for approving payments that were part of an environmental public-relations campaign. After his conviction, Drummond continued to pay David's salary and benefits for a period, but later terminated his employment. The Robersons then sued Drummond and others, asserting multiple claims, including one for indemnification. They alleged that Drummond had directed David to make the payments that were later deemed to be bribes, and that he had incurred damages as a result, for which Drummond had a duty to indemnify him. The circuit court dismissed the indemnification claim, ruling that indemnification generally comes into play in a contractual arrangement, and the Robersons had neither produced nor alleged the existence of a contract or agreement establishing such a duty. The Robersons appealed this decision.The Supreme Court of Alabama affirmed the lower court's decision. The court found that the losses the Robersons sought to recover were not indemnifiable, as they were not judicially imposed liabilities to a third party or out-of-pocket expenses that David incurred in processing the invoices. The court also found that the Robersons failed to demonstrate they had sufficiently pleaded a claim for common-law indemnification. The court rejected the Robersons' argument that Drummond's resolution to pay David's salary and benefits constituted a contract for indemnification, stating that the obligation they alleged Drummond undertook was not a promise to indemnify David, but simply a promise not to fire him. Finally, the court found that the Robersons had failed to preserve their claim for court-ordered indemnification under the Alabama Business and Nonprofit Entity Code for appellate review, as they had not asserted this argument in the trial court. View "Roberson v. Drummond Company, Inc." on Justia Law

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In the Supreme Court of Wyoming, an appeal by Ronald Pinther, a former insurance agent, was dismissed. Pinther had worked for American National Property and Casualty Insurance Company (ANPAC) and American National Insurance Company (ANICO). He filed a lawsuit against ANPAC, ANICO, and another agent, Philip Maggard, claiming breach of contract, breach of good faith and fair dealing, fraudulent inducement, promissory estoppel, civil conspiracy, and age discrimination. The district court granted summary judgment in favor of ANPAC and Mr. Maggard. On appeal, the Supreme Court held that the district court had not erred in its decision. The court found that Mr. Pinther's breach of contract claim against ANPAC was governed by the Post-Termination Compensation Schedule outlined in the agent agreement. The court further held that Mr. Pinther's claim of a breach of an implied duty of good faith and fair dealing could not be maintained given the at-will nature of the agency contract. The court also dismissed Mr. Pinther's fraudulent inducement claim against ANPAC, noting that the recruiting brochure did not govern his agreement with ANPAC. The court further held that Mr. Pinther's claim for tortious interference with a contract against Mr. Maggard could not be maintained as the actions of Mr. Maggard, as an agent of ANPAC, were imputed to ANPAC. Lastly, the court held that Mr. Pinther's civil conspiracy claims against ANPAC and Mr. Maggard failed as the underlying tort claims did not survive summary judgment. View "Pinther v. American National Property and Casualty Insurance Company" on Justia Law

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In a dispute between ORP Surgical, LLC (ORP), and Howmedica Osteonics Corp., also known as Stryker, the United States Court of Appeals for the Tenth Circuit affirmed in part and reversed in part the district court's ruling. ORP and Stryker, both involved in medical device sales, had a successful business relationship under two sales contracts, the Joint Sales Representative Agreement (JSRA) and the Trauma Sales Representative Agreement (TSRA). The relationship soured when Stryker terminated the JSRA and hired one of ORP's sales representatives, and later, when ORP terminated the TSRA, Stryker hired a dozen of ORP's representatives. The district court ruled in favor of ORP, finding that Stryker breached the sales contracts and owed ORP damages, attorneys’ fees, sanctions, and costs. On appeal, Stryker challenged the rulings on the breach of contract claims, the attorneys’ fees award, and the nominal damages award. The Court of Appeals affirmed the district court’s holdings on the breach-of-contract claims but reversed its award of attorneys' fees under the indemnification provision. It also affirmed the award of nominal damages for Stryker's breach of the non-solicitation/non-diversion provision. The case was remanded for further proceedings. View "ORP Surgical v. Howmedica Osteonics Corp." on Justia Law

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Two online fundraising companies, Snap! Mobile, Inc. ("Snap") and Vertical Raise, LLC ("Vertical Raise"), were involved in a dispute. Snap accused Vertical Raise and its CEO, Paul Landers, of poaching its sales representatives and customers, which violated non-compete and confidentiality provisions in the former sales representatives’ employment agreements with Snap. The trial court granted Snap a preliminary injunction to prevent further violations and partially ruled in Snap's favor on some claims. A jury trial on damages resulted in an award of $1,000,000 to Snap. However, the trial court increased the award to $2,310,021. Both parties appealed. The Supreme Court of Idaho affirmed the trial court's award of discretionary costs for expert witness fees but reversed the trial court’s order granting an additur or new trial. The Supreme Court ordered the trial court to enter a judgment consistent with the original jury award. The Supreme Court also reversed the trial court’s decision granting Snap a permanent injunction. In a separate contempt proceeding, the Supreme Court affirmed the contempt court's decision to dismiss contempt charges against Vertical Raise and Paul Croghan, a former Snap employee. The contempt court had determined the preliminary injunction was vague, overbroad, and unenforceable. View "Snap! Mobile v. Vertical Raise" on Justia Law

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The United States Court of Appeals for the First Circuit upheld a district court's decision concerning a wage dispute between an employee and his former employer. The employee, Paulo Trindade, claimed that his former employer, Grove Services, Inc., breached their contract and violated the Massachusetts Wage Act by short-changing him on his sales commission compensation. Grove Services challenged the timeliness of Trindade's Wage Act claim relating to the 2016 commission, but the court agreed with the district court that the claim related back to his original complaint, making it timely. The First Circuit also upheld the district court's damages award. Trindade was awarded $330,597 in damages, which included compensation for late and unpaid wages for the 2016 commission, subject to mandatory trebling under the Wage Act, and damages for the 2014 breach of contract. View "Trindade v. Grove Services, Inc." on Justia Law

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In the dispute between fashion designer and social media influencer Hayley Paige Gutman and her former employer, JLM Couture, Inc., the United States Court of Appeals for the Second Circuit considered the preliminary injunction and contempt order issued by the United States District Court for the Southern District of New York. The lower court had awarded JLM control of two social media accounts previously managed by Gutman and enforced a five-year restrictive covenant that prohibited Gutman from identifying herself as a designer of certain goods. The court also held Gutman in civil contempt for posts on Instagram that it deemed as marketing, violating an earlier version of the preliminary injunction.The Court of Appeals dismissed Gutman's appeal from the contempt order due to lack of appellate jurisdiction. It affirmed the district court's refusal to dissolve the preliminary injunction based on the law of the case. However, the Court of Appeals vacated the district court’s order that modified its preliminary injunction. The court found fault in the lower court's determination of the ownership of the disputed social media accounts and its failure to evaluate the reasonableness of the five-year noncompete restraint on Gutman. The case was remanded for further proceedings consistent with the opinion of the Court of Appeals. View "JLM Couture, Inc. v. Gutman" on Justia Law

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In this case, the plaintiff, Jordan Nissensohn, as the administrator of the Estate of Michael Nissensohn, filed a suit against University Medical Group (UMG), Dr. Alan Epstein, and Dr. Steven Sepe, alleging numerous claims including defamation, breach of contract, tortious interference with contractual relations, conversion, and violations of the Rhode Island Whistleblowers’ Protection Act (RIWPA). The Superior Court entered a judgment in favor of the defendants, granting summary judgment.The plaintiff, Dr. Michael Nissensohn, had been employed as a gastroenterologist by UMG and was supervised by Dr. Epstein. The plaintiff had a series of disagreements and conflicts with Dr. Epstein over teaching responsibilities and alleged discrepancies in teaching compensation. The plaintiff also claimed that Dr. Epstein had disclosed his mental health information to another staff member, and had spread a rumor about his mental health. Additionally, the plaintiff claimed that Dr. Epstein interfered with his prospective business relations with patients and his contract, and converted his personal laptop.The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. The court held that the plaintiff did not demonstrate that he engaged in protected conduct under the RIWPA because he did not report actual violations of the law. The court also ruled that the plaintiff's defamation claim abated upon his death and therefore did not survive. Regarding the breach of contract claim, the court found that the plaintiff failed to provide evidence of a breach of the written agreement. The court further held that the plaintiff failed to show that Dr. Epstein intended to harm his contract, which was an essential element of his claim for tortious interference. Lastly, the court found that the plaintiff failed to provide any non-hearsay evidence to prove his demand and refusal, thus failing to establish his claim for conversion. View "Nissensohn v. CharterCARE Home Health Services" on Justia Law

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This case involves a dispute between Griggs & Browne Pest Control Co., Inc. (plaintiff), and its former employee, Brian Walls (defendant). Upon hiring Walls in 2011, the parties entered into a noncompetition agreement, which was updated in 2020. The agreement stipulated that, in return for his training and access to the company's client list, Walls would refrain from soliciting business from or performing services for the company's current or former customers for 24 months after ending his employment with the company.In 2021, the company introduced a new policy requiring all employees to receive the COVID-19 vaccination or terminate their employment. Walls vocally opposed the policy and was told he could no longer resume his employment. A month later, the company discovered that Walls was contacting their former clients and performing pest-control services for them, in violation of the noncompetition agreement. The company initiated a lawsuit to prevent Walls from further violating the agreement.The Superior Court of Rhode Island granted a preliminary injunction in favor of the plaintiff, which Walls appealed. The Supreme Court of Rhode Island affirmed the lower court's decision, determining that the noncompetition agreement was valid and enforceable. The court rejected Walls' argument that he had been improperly terminated due to his refusal to receive the COVID-19 vaccine, noting that the circumstances surrounding his departure were immaterial to the enforcement of the noncompetition agreement. The court also found that the plaintiff would suffer irreparable harm due to loss of customer goodwill if Walls were allowed to continue servicing the company's clients. The balance of equities favored the plaintiff, and the injunction was necessary to uphold the status quo. Therefore, the court affirmed the lower court's decision to grant a preliminary injunction in favor of the plaintiff. View "Griggs & Browne Pest Control Co., Inc. v. Walls" on Justia Law

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In this case, the Supreme Court of the State of Idaho upheld a lower court's summary judgment in favor of the defendants, George and Jesse’s Les Schwab Tire Store, Inc., and two of its owners, Bruce and Richard Byram. The plaintiff, Adam Davis, had been employed as an assistant manager at Les Schwab from April 2016 till June 2019. In March 2019, there was a shortage in the cash deposits and surveillance footage showed Davis bending down out of camera view in the area where the cash deposits were kept while he was alone in the store. This led to Davis being arrested and charged with grand theft, and his employment was terminated. Although the charges against Davis were later dropped, he sued the defendants for breach of his employment contract, false arrest, defamation per se, and for knowingly giving a false report to the police. The district court granted the defendants’ motion for summary judgment on all of Davis’s claims. The Supreme Court affirmed the lower court's decision, finding no genuine issue of material fact that could support Davis’s claims. The court found that Davis was an at-will employee who could be terminated without cause and that there was no evidence to show that the defendants had acted with malice. The court also found that the plaintiff's attorney had violated Rule 11.2 by submitting arguments that were not well grounded in fact, and awarded a portion of the defendants' attorney fees to be paid by the plaintiff's counsel. View "Davis v. George and Jesse's Les Schwab Tire Store, Inc." on Justia Law