Justia Contracts Opinion Summaries

In these consolidated cases (Garner and Kawashima), the Supreme Court held that the circuit court erred in determining that Regulation 5203 was a Haw. Rev. Stat. chapter 91 rule and in granting summary judgment in favor of Plaintiffs for their hourly back wages contract claims. Further, the court erred in finding in the Garner case that Plaintiffs were entitled to interest on their per diem and hourly back wages under Haw. Rev. Stat. 103-10.Plaintiffs in both cases - substitute and part-time temporary teachers (PTTs) who were employed by the State, Department of Education (DOE) - claimed they were underpaid by the State. In Garner, the circuit court awarded hourly back wages to Plaintiffs who worked in a part-time capacity and also awarded interest on both the per diem and hourly back wages owed. In Kawashima, the circuit court awarded the PTTs hourly back wages but ruled that the PTTs were not entitled to interest on their unpaid hourly wages. The Supreme Court reversed the judgment in Garner and affirmed in part and reversed in part the judgment in Kawashima, holding that Plaintiffs were not entitled to hourly back wages or interest on any back wages, whether per diem or hourly, under section 103-10. View "Kawashima v. State, Department of Education" on Justia Law

Bishop & Associates, LLC (B&A) filed an action against Ameren Corp. and others (collectively, Ameren and the supervisors) alleging wrongful discharge in violation of public policy and other claims after Ameren terminated its relationship with B&A. The circuit court entered summary judgment for Ameren and the supervisors on all counts. The Supreme Court affirmed, holding (1) Missouri does not recognize a cause of action for wrongful discharge in violation of public policy for independent contractors; (2) the circuit court did not err in granting summary judgment to the defendants on B&A’s claim of breach of the implied covenant of good faith and fair dealing; (3) Missouri case law does not support breach of contract claim for wrongful termination in violation of public policy; and (4) the circuit court did not err in entering summary judgment on B&A’s tortious interference with a business expectancy claim. View "Bishop & Associates, LLC v. Ameren Corp." on Justia Law

The Eighth Circuit affirmed the district court's order compelling arbitration and dismissing plaintiff's case without prejudice where he alleged violations of minimum wage laws, as well as fraud. In this case, plaintiff signed a Volunteer Release, Waiver and Indemnification Agreement when he volunteered as a concession worker for a fundraiser. The court held that the agreement was not unconscionable under Missouri law because the agreement was easy to understand, with no evidence that it was non-negotiable. Furthermore, the agreement did not lack consideration where the consideration was that plaintiff was giving up his right to sue in return for his opportunity to volunteer and DNCS's contribution to Washington University, something neither was legally bound to do. Finally, the underlying factual allegations were covered by the arbitration provision. View "Leonard v. Delaware North Companies Sport Service, Inc." on Justia Law

Jewels by Park Lane, Inc. ("JBPL"), and Kathy Cassidy, the national director for JBPL, sought a writ of mandamus compelling the Circuit Court to vacate its order denying their motion to dismiss an action against them on the ground of improper venue arising out of a forum-selection clause, and to enter an order dismissing the case. JBPL was a multilevel marketing company that sold jewelry through independent contractors who host parties offering JBPL's jewelry line for sale. Jennifer Miller became a “director” for LBPL. Miller sued JBPL and Cassidy, alleging JBPL promised to employ her for a 12-month period and to pay her $4,000 a month for that period. Miller set out claims alleging account stated, open account, breach of contract, and fraud. Miller sought compensatory damages, punitive damages, and attorney fees. The employment agreement contained a “forum selection clause” in which any disputes between the parties would be settled in accordance with the laws of Illinois. Miller admitted that the director agreement contained a forum selection clause but argued that she would not have entered into the agreement but for the fraud perpetuated by JBPL and Cassidy. The Alabama Supreme Court concluded JBPL and Cassidy have shown a clear legal right to have the action against them dismissed on the basis that venue in the Tallapoosa Circuit Court was, by application of the outbound forum-selection clause, improper. The trial court exceeded its discretion in denying their motion to dismiss Miller's action. View "Ex parte Jewels by Park Lane, Inc." on Justia Law

MHA filed suit against defendants, two former employees, based on the alleged breach of non-compete and non-solicitation provisions in its employment contracts, tortious interference, and theft of computer files. The Fifth Circuit vacated the award of exemplary damages to MHA because there was insufficient evidence to support the award; affirmed the district court's evidentiary rulings; affirmed the district court's denial of a motion for judgment as a matter of law where the jury's verdict was consistent; affirmed the district court's take-nothing judgment in favor of Defendant Bowden; affirmed the award of attorneys' fees; and affirmed the district court's denial of equitable remedies. View "Merritt Hawkins & Assocs. v. Gresham" on Justia Law

Plaintiff filed suit against his former employer, NCC, for breach of contract and alleging claims under the Nebraska Wage Payment and Collection Act. Applying Nebraska's two-part test to determine whether an agreement was voidable as a product of duress, the court held that there was, at least, a genuine issue of material fact as to whether the threat of termination would support a claim of duress. Therefore, the court remanded for a determination of this factual issue. The court also held that, considering all relevant circumstances then existing and viewing the facts in the light most favorable to plaintiff, the Term Sheet was unjust and thus voidable as a product of duress given the alleged pressure brought to bear on him to sign the Mutual Rescission and Term Sheet. Therefore, the district court erred by granting summary judgment for NCC on the breach of contract claim. Likewise, the district court erred in granting summary judgment for NCC on the state law claim. View "Gilkerson v. Nebraska Colocation Centers" on Justia Law

In 2015, RPM Cranes and its owner Muhammad Wasim Ali sued the defendants CraneWorks, Inc. and its owners, David Upton ("David") and Steve Upton ("Steve"), and Russell Brooks, Rick Yates, and Casey Markos, alleging that Brooks, Yates, and Markos had violated their employment agreements by going to work for CraneWorks and that CraneWorks' hiring of Brooks, Yates, and Markos likewise violated those employment agreements. David and Steve were named as defendants by virtue of their ownership of CraneWorks. RPM and Ali sought monetary damages and injunctive relief. The trial court entered a permanent injunction in favor of RPM and Ali and against the defendants. The Alabama Supreme Court found the injunction at issue in defendants' appeal was not specific in its scope: the order stated that the defendants were "permanently restrained and enjoined from contacting, in any way, whatsoever, any of those clients which are now clients of RPM Cranes." The order failed, however, to specify which clients were included in the injunction. RPM and Ali introduced no evidence as to who RPM's clients were or whether it had developed any clients of its own that Yates and Brooks did not bring onboard as a result of their previous jobs with other entities. In other words, the injunction was broad and vague rather than "specific in [its] terms." The Court reversed the trial court's order and remanded for further proceedings. View "Brooks v. RPM Cranes, LLC" on Justia Law

This action stemmed from a “without cause” termination of Plaintiff’s five-year employment contract at the end of his third contract year. Plaintiff brought claims against his former employer, its chief executive officer, and its professional services company for, inter alia, breach of contract and tortious interference with contract. The trial court granted summary judgment for Defendants. The court of appeals reversed the trial court’s dismissal of the claims for breach of contract and tortious interference. The Supreme Court reversed the judgment of the court of appeals and reinstated the trial court’s judgment in favor of Defendants, holding (1) the employer was entitled to summary judgment on the breach of contract claim where the employer was not required to prove the reasons it terminated Plaintiff’s employment contract “without cause” an the relevant provisions of the contract were not ambiguous; (2) Defendants were entitled to summary judgment on the tortious interference claim where Plaintiff presented no evidence of willful or intentional interference; and (3) the employer’s professional services company was entitled to Plaintiff’s tortious interference claim where it conclusively established its justification defense to the claim. View "Community Health Systems Professional Services Corp. v. Hansen" on Justia Law

A civil service employee may enter into a valid last-chance agreement, which remains subject to principles of contract law, and the civil service commission need not sanction the agreement for it to be effective.A municipal firefighter pled guilty to domestic abuse assault. The municipality offered to discipline him instead of terminating his employment but required that the firefighter agree that the municipality have the discretion to terminate him immediately and without appeal if he violated the related no-contact order. The firefighter agreed to the proposal and signed a written "last-chance agreement." One year later, the firefighter violated the no-contact order, and the municipality terminated the firefighter’s employment in reliance on the agreement. The firefighter attempted to appeal, but the civil service commission declined to hear the appeal. The district court, however, concluded that the last-chance agreement was invalid because the commission had not approved or reviewed it before the parties entered into it. The Supreme Court reversed, holding that the last-chance agreement in this case was valid and enforceable. View "Whitwer v. Civil Service Commission of the City of Sioux City" on Justia Law

A jury awarded Plaintiff future lost profits based on Defendants’ failure to comply with their covenants not to compete and covenants not to solicit. The jury also awarded Plaintiff exemplary damages and attorney fees. The trial court awarded Plaintiff the full amount of damages. The court of appeals reversed and rendered a take-nothing judgment in part and remanded in part, concluding, inter alia, that the evidence was legally insufficient to support the jury’s award of future lost profits and that the exemplary damages award was unconstitutionally excessive. The Supreme Court affirmed in part and reversed in part, holding (1) the court of appeals did not err in concluding that the evidence of future lost profits was legally insufficient; (2) the court of appeals’ remitted exemplary damages award was unconstitutionally excessive; and (3) the court of appeals properly found that remand of the issue of attorney’s fees was proper. The court remanded the case to the court of appeals so that it may reconsider its suggested remittitur of exemplary damages. View "Horizon Health Corp. v. Acadia Healthcare Co." on Justia Law