Justia Contracts Opinion Summaries

Plaintiff Tony Muro entered into an employment contract with defendant Cornerstone Staffing Solutions, Inc. (Cornerstone). The contract included a provision requiring that all disputes arising out of Muro's employment with Cornerstone to be resolved by arbitration. It also incorporated a class action waiver provision. In response to this case, which was styled as a proposed class action and alleged various Labor Code violations, Cornerstone moved to compel arbitration and dismiss the class claims. Relying heavily on Garrido v. Air Liquide Industrial, U.S. LP, 241 Cal.App.4th 833 (2015), the trial court concluded the contract was exempted from the operation of the Federal Arbitration Act (FAA; 9 U.S.C. 1 et seq.) and was instead governed by California law. It further determined that the California Supreme Court's decision in Gentry v. Superior Court, 42 Cal.4th 443 (2007) (overruled by 59 Cal.4th 348(2014)) continued to provide the relevant framework for evaluating whether the class waiver provision in the contract was enforceable under California law. After applying Gentry to the record here, the court found the class waiver provision of the contract unenforceable and denied the motion to compel arbitration. Cornerstone appeals, but finding no error, the Court of Appeal affirmed. View "Muro v. Cornerstone Staffing Solutions" on Justia Law

In 1998, CNH agreed to a collective-bargaining agreement (CBA), providing health care benefits under a group benefit plan to “[e]mployees who retire under the . . . Pension Plan.” “All other coverages,” such as life insurance, ceased upon retirement. The group benefit plan was “made part of ” the CBA and ran concurrently with it. The agreement contained a general durational clause stating that it would terminate in 2004 and stated that it “dispose[d] of any and all bargaining issues, whether or not presented during negotiations.” When the agreement expired, a class of CNH retirees sought a declaration that their health care benefits vested for life. In 2015, while their lawsuit was pending, the Supreme Court decided “Tackett,” requiring interpretation of CBAs according to “ordinary principles of contract law.” The Sixth Circuit concluded that the 1998 agreement was ambiguous and that extrinsic evidence supported lifetime vesting. The Supreme Court reversed. The Sixth Circuit erred in finding that the agreement was ambiguous based on a presumption, from pre-Tackett precedent, that lifetime vesting was inferred whenever “a contract is silent as to the duration of retiree benefits” and in declining to apply the general duration clause. Such inferences are inconsistent with ordinary principles of contract law. A contract is not ambiguous unless it is subject to more than one reasonable interpretation. View "CNH Industrial N. V. v. Reese" on Justia Law

In this action brought by Plaintiff alleging a deliberate intent claim and violations of the West Virginia Human Rights Act (Act) the Supreme Court reversed the circuit court’s rulings and remanded the case for entry of an order dismissing the action and compelling arbitration.Plaintiff instituted this civil action against Hampden Coal, LLC, his employer, and his supervisor alleging a deliberate intent claim related to his workplace injury and two violations of the Act arising from his demotion. Defendants filed a motion to dismiss or, in the alternative, to compel arbitration pursuant to an arbitration agreement Appellant signed as a condition of his employment. The circuit court denied Defendants’ motion to dismiss and refused to compel arbitration, concluding, among other things, that the arbitration agreement was invalid because it lacked consideration and was both substantively and procedurally unconscionable. The Supreme Court reversed, holding (1) more stringent or different standards do not apply to consideration of arbitration agreements in the employment context; (2) the parties’ agreement to arbitrate their disputes served as consideration for the agreement; (3) the agreement was neither substantively or procedurally unconscionable; (4) Plaintiff’s claims did not fall outside the scope of the agreement; and (5) the circuit court erred in finding that the agreement was an employment contract. View "Hampden Coal, LLC v. Varney" on Justia Law

Plaintiff Stacy Gaasch, as personal representative for the Estate of Troy Gaasch, filed suit against St. Paul File and Marine Insurance Company, alleging the insurance company failed to timely provide reasonable and necessary medical treatment as ordered by the Workers' Compensation Court. Troy required multiple surgeries over several years due to his work-related injury. Troy was hospitalized due to his work-related injury. He allegedly became malnourished with accompanying weight loss and different physicians recommended a nutritional consult. A nurse case manager recommended monthly a nutritional consult. Troy died during his hospitalization approximately six months after the initial recommendation for a nutritional consult. Prior to his work-related injury, Troy underwent a gastric bypass surgery and allegedly suffered from a malabsorption syndrome secondary to this surgery. A disagreement arose between insurer and Troy concerning whether the insurer was required to pay for a nutritional consult. Insurer claimed Troy's nutritional problems were created prior to his work-related injury and his nutritional state in the hospital was not due to the work-related injury. The company moved for summary judgment which was granted. Plaintiff appealed. The Oklahoma Supreme Court held: (1) Plaintiff's district court action alleging breach of contract also included a request for damages resulting from the death of the workers' compensation claimant; (2) the district court action was based upon alleged delay by a workers' compensation insurer in providing medical care as previously awarded by the Worker's Compensation Court; and (3) the district court action against the workers' compensation insurer was precluded by an exclusive remedy provided by the Workers' Compensation Act. “Plaintiff attempts to go around this procedure we classified as a ‘jurisdictional requirement’ . . .by characterizing the claim as a breach of contract and an action for damages resulting from an alleged wrongful death. The clear public policy expressed in the amended version of Art. 23 sec. 7 requires available workers' compensation remedies for any type of wrongful death claim to be pursued in the Workers' Compensation Court when required by the workers' compensation statutes.” View "Gaasch v. St. Paul Fire & Marine Ins. Co." on Justia Law

Plaintiff and the corporate Defendants freely negotiated and entered into a clear and unambiguous contract for Plaintiff to sell their insurance policies. In the contract, Plaintiff consented to a provision allowing Defendants to immediately terminate the contract if he breached it in any one of five different specified ways. Plaintiff breached the contract, and Defendants exercised their right to terminate. Plaintiff sued Defendants under numerous theories of liability for terminating the contract, including under the doctrine of prima facie tort, asserting that Defendants had nefarious reasons for terminating the contract. After review, the New Mexico Supreme Court held that when a contract is clear, unambiguous, and freely entered into, the public policy favoring freedom of contract precludes a cause of action for prima facie tort when the gravamen of the allegedly tortious action was the defendant’s exercise of a contractual right. View "Beaudry v. Farmers Ins. Exch." on Justia Law

Plaintiff and the corporate Defendants freely negotiated and entered into a clear and unambiguous contract for Plaintiff to sell their insurance policies. In the contract, Plaintiff consented to a provision allowing Defendants to immediately terminate the contract if he breached it in any one of five different specified ways. Plaintiff breached the contract, and Defendants exercised their right to terminate. Plaintiff sued Defendants under numerous theories of liability for terminating the contract, including under the doctrine of prima facie tort, asserting that Defendants had nefarious reasons for terminating the contract. After review, the New Mexico Supreme Court held that when a contract is clear, unambiguous, and freely entered into, the public policy favoring freedom of contract precludes a cause of action for prima facie tort when the gravamen of the allegedly tortious action was the defendant’s exercise of a contractual right. View "Beaudry v. Farmers Ins. Exch." on Justia Law

Although Wis. Stat. 103.465 explicitly refers to a covenant not to compete, the plain meaning of the statute is not limited to covenant in which an employee agrees not to compete with a former employer.Plaintiff imposed a non-solicitation of employees provision as part of Defendant’s employment agreement. The provision prohibited Defendant from soliciting, inducing, or encouraging any employee of Plaintiff to terminate his or her employment or to accept employment with a competitor, supplier or customer of Plaintiff. Plaintiff claimed that Defendant engaged in actions that violated the non-solicitation of employees provision. The circuit court concluded that the provision was reasonable and enforceable under section 103.465. The court of appeals reversed. The Supreme Court affirmed, holding that Defendant’s non-solicitation of employees provision was a restraint of trade governed by section 103.465 and was unenforceable under the statute because it did not meet the statutory requirement that the restriction be “reasonably necessary for the protection of the employer.” View "Manitowoc Co. v. Lanning" on Justia Law

The patent, entitled “Full Duplex Single Clip Video Codec” lists co-inventors, Woo, Li, and Hsiun, and was created while they were Infochips employees. Infochips’ “receivables,” pledged as security, were seized by LM when Infochips went out of business in 1993; in 1995, LM sold Infochips’s assets to Woo. Woo assigned his interest in the patent to AVC. In 1995, AVC filed the patent's parent application. Woo and Li assigned their interests to AVC. Hsiun refused to do so. The PTO permitted AVC to prosecute the application without that assignment. AVC claimed that it obtained Hsiun’s interests by Hsiun's 1992 Employment Agreement with Infochips. The patent was issued to AVC, which later dissolved, after purporting to transfer its assets to its successors (Advanced Video). In 2011, Advanced Video filed patent infringement lawsuits. The district court found that AVC had not complied with Delaware statutes governing dissolved corporations and that no patent rights had transferred to Advanced Video. The cases were dismissed. The state court appointed a Receiver to transfer AVC's patent rights to Advanced Video. After the transfer, Advanced Video filed new infringement lawsuits, arguing that its acquisition of Hsiun’s interest was effected by the Employment Agreement’s “will assign,” trust and quitclaim provisions. The court rejected the argument and, because Hsiun was not a party to the suit, dismissed for lack of standing. The Federal Circuit affirmed. Hsiun never actually assigned her rights, despite her promises to do so. View "Advanced Video Technologies, LLC v. HTC Corp." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to at-will employees in an action alleging breach of contract against Panera. Plaintiffs filed suit on behalf of themselves and a class of similarly situated store managers, alleging that Panera violated employee agreements by imposing a bonus cap. The court noted that under Missouri law, the agreements amounted to offers by Panera to enter into an unilateral contract; the court held that the Supreme Court of Missouri would conclude that an offerree must merely begin performance; and since each of the managers in the class here had at least begun performing under the offer, Panera could not modify the offer terms as to any manager. The court rejected Panera's contention that it reserved the power to modify or terminate its bonus offer before the managers began performing in accordance with that offer, and Panera's derivative argument that the district court should have revisited its decision to certify the class after determining that the bonus offers were offers to make a unilateral contract. Finally, the court affirmed the district court's rejection of Panera's novation, waiver, estoppel, and commercial frustration defenses. View "Boswell v. Panera Bread Co." on Justia Law

The Supreme Court affirmed the order of the circuit court granting summary judgment in favor of Employer and certain members of its management staff in this suit brought by Employee after Employee was terminated for allegedly slapping and secluding a senior care facility resident. The Supreme Court held that the circuit court properly granted summary judgment against Employee on his slander claim, intentional infliction of emotional distress claim, malicious prosecution claim, claim for punitive damages, wrongful termination claim, negligent infliction of emotional distress claim, and breach of contract claim. View "Harvey v. Regional Health Network" on Justia Law