Justia Contracts Opinion Summaries

The Supreme Court affirmed the district court's grant of summary judgment to a local teachers' union in this union contract dispute, holding that the local union validly terminated the contract and so was not contractually obligated to continue transmitting its members' dues to the state union.The Clark County Education Association (CCEA) was a local union representing teachers and other school district employees. The Nevada State Education Association (NSEA) and the National Education Association (NSA) were its statewide and national affiliates. NSEA and CCEA entered into a contract requiring CCEA to transmit NSEA and NEA dues after receiving them from the school district. In 2017, CCEA notified NSEA that it wanted to terminate the contract and negotiate new terms. No new agreement was forthcoming, but CCEA continued to collect union dues but placed the portion of the NSEA dues in an escrow account pending litigation. CCEA filed an action seeking a declaration that it had no obligation to transmit the money to NSEA. NSEA and NEA filed a separate action for declaratory and injunctive relief. The district court granted judgment to CCEA on all claims. The Supreme Court affirmed, holding that CCEA lacked a contractual obligation to transmit the dues and properly placed them in escrow pending resolution of this dispute. View "Nevada State Education Ass'n v. Clark County Education Ass'n" on Justia Law

After plaintiff prevailed on her procedural due process and breach of contract claims against TSC, the trial court vacated the jury's verdict on the breach of contract claims and reduced the damages award on her procedural due process claim to $1.The Fifth Circuit held that TSC is entitled to neither sovereign immunity under the United States Constitution nor governmental immunity under state law. In this case, the Texas Legislature abrogated TSC's governmental immunity such that plaintiff could bring state law breach of contract claims against TSC. Therefore, the argument that the Texas Legislature attempted to limit federal jurisdiction over these claims is unavailing. The court also held that it was not required to address TSC's alternative arguments and declined to do so. The court reversed the dismissal of plaintiff's breach of contract claims, reinstated the jury's verdict on those claims, and remanded for the district court to consider TSC's alternative arguments regarding whether sufficient evidence supports plaintiff's breach of contract claims. The court affirmed the district court's grant of judgment as a matter of law on the due process violation damages and reduction of the jury's award of $12,500,000 to the nominal amount of $1. The court reversed the district court's vacatur of the portion of the attorneys' fees award based on the breach of contract claims and remanded for the district court to address TSC's alternative arguments regarding those claims and to determine whether plaintiff is entitled to attorneys' fees and in what amount. View "Tercero v. Texas Southmost College District" on Justia Law

Plaintiff Jed Goldfarb claimed defendant David Solimine reneged on a promise of employment after Goldfarb quit his job to accept the promised position managing the sizeable investment portfolio of defendant’s family. The key issue in this appeal involved whether plaintiff could bring a promissory estoppel claim because he relied on defendant’s promise in quitting his prior employment even though, under New Jersey’s Uniform Securities Law of 1997 (Securities Law or the Act), he could not bring a suit on the employment agreement itself. The New Jersey Supreme Court determined the Securities Law did not bar plaintiff’s promissory estoppel claim for reliance damages. The Court affirmed the liability judgment on that claim and the remanded for a new damages trial in which plaintiff would have the opportunity to prove reliance damages. The Court found he was not entitled to benefit-of-the-bargain damages. To the extent that the Appellate Division relied on an alternative basis for its liability holding -- that a later-adopted federal law “family office” exception had been incorporated into the Securities Law -- the Court rejected that reasoning and voided that portion of the appellate court’s analysis. View "Goldfarb v. Solimine" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court granting the City of Plainview's motion to dismiss Donald Hall's contract and statutory claims, holding that the City had a contractual obligation to pay accrued paid time off (PTO) to Hall.After the City terminated Hall's employment as manager of the City's municipal liquor store it refused to pay Hall accrued PTO due to Hall's failure to provide sufficient notice per the requirements of the City's personnel policies and procedures manual. Hall sued the City for breach of contract and violation of Minn. Stat. 181.13. The district court dismissed Hall's contract and statutory claims. The Supreme Court remanded the case, holding (1) disclaimer provisions in the City's employee handbook stating that the handbook's policies should not be construed as a contract did not unambiguously allow the City to refuse to pay accrued PTO in accordance with the employer policy set forth in the handbook; and (2) Minn. Stat. 181.13(a) does not create an independent substantive right to payment of accrued PTO in the absence of a contract between the employer and employee. View "Hall v. City of Plainview" on Justia Law

The Supreme Court affirmed the order of the district court granting a preliminary injunction based on a blue-penciled noncompetition agreement, holding that Golden Road Motor Inn, Inc. v. Islam, 376 P.3d 151, 159 (Nev. 2016), does not prohibit a district court from blue-penciling an unreasonable noncompetition agreement if the agreement allows for it.Defendants signed an employment contract containing a blue-penciling provision providing that, if any provision is found to be unreasonable by the court, the provision shall be enforceable to the extent the court deemed it unreasonable. When Defendants quit their employment and began work elsewhere, Plaintiff filed a complaint to enforce the agreement, alleging that Defendants violated the agreement's noncompetition clause. The district court found that the noncompetition agreement was overbroad and blue-penciled it. The court then granted Plaintiff's motion for a preliminary injunction to enforce the revised agreement. The Supreme Court affirmed, holding that because the noncompetition agreement had a blue-penciling provision, the district court did not abuse its discretion by blue-penciling the noncompetition agreement and enforcing the revised agreement. View "Duong v. Fielden Hanson Isaacs Miyada Robison Yeh, Ltd." on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiff's disability discrimination suit against the United States Patent and Trademark Office and its director, holding that the district court did not err.The district court dismissed the action on the grounds that Plaintiff waived his discrimination claim in a settlement agreement that allowed him to resign from his job instead of being terminated. On appeal, Plaintiff argued that the district court erred in finding that his allegation of an unenforceable waiver was implausible. Specifically, Plaintiff argued that the agreement was void because he did not knowingly and voluntarily agree to it. The First Circuit disagreed, holding that the district court properly concluded that the waiver was binding. View "Perez-Tolentino v. Iancu" on Justia Law

Originally, Western Pacific Timber, LLC (WPT) was solely owned by Timothy Blixseth (Blixseth). Andrew Hawes contended Blixseth hired him to be general counsel for WPT in 2005, and that when he was hired, Blixseth agreed on behalf of WPT to provide him with a severance package based on the length of his employment. After 2012, Blixseth no longer retained any ownership interest or management responsibility in WPT. When WPT terminated Hawes’ employment in 2017, Hawes asserted that he had a severance agreement in place that had been negotiated with Blixseth on behalf of WPT, by which he would receive $100,000 for each year of employment, capped at five years, for a total of $500,000. However, Hawes could not produce a signed copy of any agreement. WPT refused to pay the claimed severance pay, and instead offered a significantly smaller severance package. Hawes rejected WPT’s offer. Hawes then sued WPT for breach of contract. The case proceeded to trial on Hawes’ claim of an oral contract. Ultimately, the jury returned a special verdict finding that WPT was liable to Hawes for $500,000 in severance pay, an award which was later trebled by the district court. The district court also awarded Hawes the full amount of his requested attorney fees which constituted 35% of Hawes’ gross recovery. WPT unsuccessfully moved for a new trial. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Hawes v. Western Pacific Timber LLC" on Justia Law

Auge, an experienced industrial-equipment salesman, started with Fairchild in 2013, with a base salary of $50,000 and a commission of 30% on the gross profits from most new equipment sales. Days after the company’s plan for calculating compensation changed in 2017, Auge abruptly quit. Fairchild deposited his commissions into his bank account. He demanded more. He believed he was entitled to a 30% commission on all anticipated gross profits, not just those “booked” in 2017. He also requested immediate payment on several “rental purchase option[s],” even though Fairchild’s policy was not to pay commissions on these rent-to-own arrangements until the end of the rental term. In Fairchild’s view, Auge lost those commissions once he quit.Auge sued for breach of contract and for alleged violations of the Minnesota Payment of Wages Act. The district court dismissed the suit. The Eighth Circuit affirmed in part but reversed with respect to “rental purchase options,” finding the contract provision ambiguous so that summary judgment was inappropriate. Fairchild owed Auge nothing for other commission, so the Act did not apply. View "Auge v. Fairchild Equipment, Inc." on Justia Law

Plaintiff-respondent Sarah Coughenour worked for defendant-appellant Del Taco, LLC, starting when she was 16 years old. When she was first employed by Del Taco, she signed a “Mutual Agreement to Arbitrate” (Agreement). After Coughenour reached the age of 18, she continued working for Del Taco for four months. Coughenour quit and filed a lawsuit against Del Taco for sexual harassment committed by one of their employees, wage and hour claims brought pursuant to the Labor Code, and other claims under the Fair Housing and Employment Housing Act. Del Taco moved to compel arbitration. The trial court denied the Motion, finding that Coughenour’s filing of the lawsuit was a disaffirmance of the Agreement within the meaning of Family Code section 6710, which allowed a person upon reaching majority age to disaffirm a contract entered into while a minor. Del Taco appealed the denial of its motion, arguing that by working for Del Taco for four months after she reached the age of majority, Coughenour ratified the Agreement, which estopped her power to disaffirm the Agreement. In the alternative, Del Taco argued that Coughenour did not disaffirm the Agreement within a “reasonable time” after reaching the age of 18 as required by Family Code section 6710. The Court of Appeal affirmed denial of Del Taco's motion: [t]he filing of the lawsuit was notice that [Coughenour] disaffirmed the Agreement." The trial court did not abuse its discretion by concluding that Coughenour disaffirmed the Agreement within a reasonable time. View "Coughenour v. Del Taco" on Justia Law

Alleshouse and Yeh are named as the inventors on the 685 and 189 patents, which claim water-park attractions that individuals may ride as if surfing, and on the 433 patent, which claims nozzle configurations for regulating water flow in such attractions. Pacific, the company Alleshouse and Yeh formed to develop and market such attractions, is the assignee of the patents. Whitewater is the successor of Wave, which employed Alleshouse until just before he went into business with Yeh and the patented inventions were conceived. Whitewater sued Alleshouse, Yeh, and Pacific, claiming that Alleshouse had to assign each of the patents to Whitewater, as Wave’s successor, under the terms of Alleshouse’s employment contract with Wave. Whitewater also claimed that Yeh, who had not been employed by Whitewater or its predecessors and therefore was not under any alleged assignment duty, was improperly listed as an inventor on each of the patents.The district court held that Alleshouse breached the employment agreement, so Whitewater was entitled to an assignment of the patent interests, and Yeh was improperly joined as an inventor. The Federal Circuit reversed, The contract’s assignment provision is void under California law, (Labor Code 2870, 2872; Business and Professions Code 16600), so Whitewater lacks standing to contest inventorship. View "Whitewater West Industries Ltd. v. Alleshouse" on Justia Law