Justia Contracts Opinion Summaries

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

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

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

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

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

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

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

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

A married couple who owned a small dental practice, D.L. Markham DDS, MSD, Inc., established an employee pension benefit plan for their business. They hired Variable Annuity Life Insurance Company (VALIC) to maintain the plan. Dissatisfied with VALIC's services, they decided to terminate their contract and were informed by VALIC that they would be charged a 5% surrender fee on all of the plan’s assets. The couple sued, alleging VALIC violated the Employee Retirement Income Security Act of 1974 (ERISA) by breaching its fiduciary duties and engaging in a prohibited transaction. The United States Court of Appeals for the Fifth Circuit affirmed the district court's dismissal of their claims. The court held that VALIC did not act as a fiduciary when it collected the surrender fee, as it simply adhered to the contract by collecting the previously agreed-upon compensation. The court also found that VALIC was not a "party in interest" when it entered the contract, as it had not yet begun providing services to the plan. Finally, the court held that VALIC's collection of the surrender fee did not constitute a separate transaction under ERISA, as it was a payment in accordance with an existing agreement. The court also affirmed the district court’s denial of the plaintiffs’ request to amend their complaint due to undue delay and insufficient detail of their new allegations. View "Markham v. Variable Annuity Life" on Justia Law

In the case before the Supreme Court of the State of Montana, the plaintiff, Kevin Barber, appealed against his former employer, Bradford Aquatic Group, LLC, alleging wrongful termination. Bradford Aquatic Group, a North Carolina-based company, had employed Barber as a Regional Business Development Manager for its Rocky Mountain region, which includes Montana. The employment contract between Barber and the company included a choice-of-law and forum selection clause, specifying that any disputes arising from the agreement would be governed by North Carolina law and adjudicated in North Carolina courts.Barber, a resident of Montana, argued that Montana law should apply to his claims of wrongful discharge, breach of contract, and bad faith, and that the suit should be heard in Montana. The district court dismissed Barber's claims due to improper venue, based on the choice-of-law and forum selection clauses in the employment agreement.Upon review, the Supreme Court of the State of Montana affirmed the district court's decision. The court found that the choice-of-law provision in the employment agreement was valid and that North Carolina law should apply to Barber's claims. The court also upheld the validity of the forum selection clause, concluding that it is enforceable under North Carolina law. Therefore, the court determined that the dispute should be adjudicated in North Carolina, not Montana. View "Barber v. Bradford Aquatic" on Justia Law