Justia Contracts Opinion Summaries

Milwaukee County calculates pension payments for its retired employees by multiplying a retiree’s final average salary by a certain percentage known as a multiplier. The resulting number is then multiplied by the retiree’s total years of county service. Suzanne Stoker and her labor union filed a complaint against the County and the Milwaukee County Pension Board, arguing that an ordinance passed by the County in 2011 that reduced the multiplier for all county service performed on or after the effective date of the ordinance was a breach of contract because she had a vested right to have the former, higher multiplier apply to her post-2011 county service and because she did not personally consent to the reduction. The circuit court granted summary judgment and declaratory and injunctive relief to Plaintiffs. The Supreme Court reversed, holding that the County did not breach Stoker’s contractual right to retirement system benefits earned and vested when it amended the pension multiplier, and the County did have the ability to make the reductions of the multiplier without Stoker’s personal consent. Remanded. View "Suzanne Stoker v. Milwaukee County" on Justia Law

In 1997, Appellant began working for Banco Popular de Puerto Rico (BPPR). After Appellant retired in 2009, BPPR made a final calculation of Appellant’s pension, which yielded monthly payments significantly lower than earlier estimates had suggested. Seeking the higher amount he had expected, Appellant brought claims under ERISA, a theory of estoppel, and Puerto Rico contract law. The district court (1) dismissed the ERISA and contract claims, concluding that Appellant failed to state a claim under ERISA and that ERISA preempted the commonwealth claims; and (2) granted summary judgment against Appellant on the estoppel claim, concluding that the unambiguous terms of the benefits plan precluded a claim for estoppel. The First Circuit affirmed, holding (1) Appellant could not recover under ERISA because he could not be awarded relief under the terms of BPPR’s retirement plan; (2) the district court properly held that Appellant’s commonwealth claims “relate to” the ERISA-regulated plan and, accordingly, they were preempted; and (3) because Appellant did not show any ambiguity in the plan, his equitable estoppel claim necessarily failed. View "Guerra-Delgado v. Banco Popular de P.R." on Justia Law

Danko practiced law with the firm of O’Reilly & Collins, until, in 2009, Danko sued O’Reilly, as an individual, and O’Reilly & Collins, for unpaid wages. Before trial, O’Reilly, as an individual, obtained directed verdict. In 2012, judgment was entered in favor of Danko for more than $2,000,000. Danko filed moved to amend the judgment and the costs and fee order “to include Terry O’Reilly as a judgment debtor for all amounts owed to Michael Danko” on the ground that O’Reilly knew that the firm owed Danko more than $2 million, but drew out all the firm’s available funds without reserving any amounts to satisfy the debt he knew was owed to Danko, telling Danko “you will not be able to execute on any judgment.” The court of appeal affirmed the trial court’s amendment of the judgment, citing Code Civ. Proc., 187. The court rejected arguments that the amendment was entered in violation of a stay in the bankruptcy of the firm; the amendment was precluded by the doctrine of res judicata; and the amendment was contrary to the principles governing collateral estoppel. View "Danko v. O'Reilly" on Justia Law

Pacific Corporate Group Holdings, LLC (PCGH) sued one of its former employees, Thomas Keck, seeking to collect on a promissory note. Keck defended against the action by claiming that any money that he owed PCGH was offset by monies that PCGH owed him. Keck also filed a cross-complaint against PCGH seeking damages for unpaid bonus and severance payments that he claimed were due to him pursuant to two employment agreements. In a special verdict, the jury found that PCGH owed Keck $270,547.95 under the terms of a 2006 employment agreement. PCGH filed a motion for judgment notwithstanding the verdict (JNOV) or for new trial on the ground that there was no substantial evidence to support the jury's finding that the parties entered into the 2006 Agreement. The trial court denied PCGH's motion. Keck filed a motion for additur, or in the alternative, for a new trial on damages, on the ground that the jury had awarded inadequate damages in light of the bonus and severance provisions in the 2006 Agreement. The trial court granted Keck's motion, and issued an additur and conditional order granting a new trial on damages. PCGH refused to consent to the additur, and thus, the trial court's order directing a new trial on damages became effective. Both parties filed motions for attorney fees, which the court denied. PCGH filed two appeals seeking reversal of the judgment: the trial court's order denying its motion for new trial and JNOV; and the trial court's order granting Keck's motion for additur, or, in the alternative, a new trial on damages; and the trial court's order denying its motion for attorney fees. Keck appealed the trial court's order denying his motion for attorney fees. The Court of Appeal concluded that the trial court's order granting a new trial on damages resulted in a vacatur of the underlying judgment, and therefore, the Court lacked appellate jurisdiction to consider PCGH's appeals, the trial court's order denying its motion for new trial, and the trial court's order denying attorney fees. Furthermore, the Court concluded that it lacked appellate jurisdiction to consider Keck's appeal of the trial court's order denying attorney fees. The Court affirmed both the trial court's order denying PCGH's motion for JNOV and the trial court's order granting Keck's motion for additur, or in the alternative, a new trial on damages. The case was remanded back to the trial court with directions to conduct a new trial on damages and any other necessary proceedings. View "Pacific Corporate Group Holdings v. Keck" on Justia Law

After Plaintiff was terminated from his employment with NCR Corporation, Plaintiff brought suit, alleging thirteen causes of action. The district court dismissed eleven of Plaintiff’s claims pursuant to Utah R. Civ. P. 12(b)(6). The district court subsequently granted summary judgment to Defendant on Plaintiff’s remaining two claims for wrongful discharge in breach of an employment contract and breach of the implied covenant of good faith and fair dealing. Specifically, the court concluded that Plaintiff had failed to present evidence of an employment contract between the parties sufficient to overcome the presumption of at-will employment under Utah law. The court of appeals reversed the district court’s grant of summary judgment, concluding that NCR’s corporate policy manual could be read to create an implied contract rebutting the presumption that Plaintiff was an at-will employee. The Supreme Court reversed, holding that the court of appeals erred in determining that the language contained in NCR’s policy manual evidenced an intent to form an implied-in-fact contract sufficient to overcome the presumption of at-will employment. View "Tomlinson v. NCR Corp." on Justia Law

Appellee was employed by Appellant on two separate occasions. On each occasion, Appellee signed a noncompete agreement. After Appellee’s second term of employment ended he filed a complaint seeking a declaratory judgment that the noncompete agreements were unenforceable. The district court entered declaratory judgment in favor of Appellee, determining that the noncompete agreements were unreasonable and unenforceable because the scope of the noncompete agreements was greater than reasonably necessary to protect Appellant against unfair competition. The Supreme Court affirmed, holding that the applicable noncompete agreement was greater than reasonably necessary to protect the legitimate interests of Appellant and was therefore unreasonable and unenforceable.View "Gaver v. Schneider’s O.K. Tire Co." on Justia Law

Plaintiffs Brett Woods and Kathleen Valdes were state employees and representatives of a class of New Mexico state and local government employees who alleged they paid for insurance coverage through payroll deductions and premiums pursuant to a policy issued by Standard Insurance Company (Standard), but did not receive the coverage for which they paid and, in some cases, were denied coverage entirely. Plaintiffs filed suit in New Mexico state court against three defendants: Standard, an Oregon company that agreed to provide the subject insurance coverage; the Risk Management Division of the New Mexico General Services Department (the Division), the state agency that contracted with Standard and was responsible for administering benefits under the policy; and Standard employee Martha Quintana, who Plaintiffs allege was responsible for managing the Division’s account with Standard and for providing account management and customer service to the Division and state employees. Plaintiffs' ninety-one-paragraph complaint, stated causes of action against Standard and the Division for breach of contract and unjust enrichment; against Standard for breach of fiduciary duty, breach of the implied duty of good faith and fair dealing, and Unfair Practices Act violations; and against Standard and Ms. Quintana for breach of the New Mexico Trade Practices and Fraud Act. The issue this appeal presented for the Tenth Circuit's review centered on whether remand to the state court pursuant to the Class Action Fairness Act (CAFA) was required under either of two CAFA provisions: the state action provision, which excludes from federal jurisdiction cases in which the primary defendants are states; or the local controversy exception, which requires federal courts to decline jurisdiction where, among other things, there is a local defendant whose alleged conduct forms a significant basis for the claims asserted by plaintiffs and from whom plaintiffs seek significant relief. The Court concluded that neither provision provided a basis for remand, and therefore reversed the decision of the magistrate judge remanding the case to state court. But because the Tenth Circuit could not determine whether Defendants have established the amount in controversy required to confer federal jurisdiction, the case was remanded to the district court for the resolution of that issue.View "Woods v. Standard Insurance Co." on Justia Law

Plaintiff Lori Edwards appealed a trial court's ruling denying her petition for writ of mandate, challenging Edwards's classification and payment as a substitute teacher for the 2007/2008 school year. Edwards contends that, because she provided teaching services during the entire school year, she was a permanent employee and therefore was unlawfully deprived of backpay for the 2007/2008 school year. Edwards also argued the trial court erred in finding her writ petition barred by the three-year statute of limitations. Upon review of the matter, the Court of Appeal concluded Edwards's writ petition was not barred by the statute of limitations because the limitation period was tolled while Edwards was pursuing internal administrative remedies. Nevertheless, the Court concluded the trial court did not err in denying Edwards's petition on the grounds the Lake Elsinore Unified School District did not misclassify Edwards as a substitute teacher and was not required to pay Edwards backpay.View "Edwards v. Lake Elsinore Unified etc." on Justia Law

At issue in this lawsuit was whether workers engaged in testing and inspection of fire protection equipment are covered by New York’s prevailing wage statute. The New York State Department of Labor issued an opinion letter stating that the workers were covered but that the opinion shall be applied prospectively. The United States Court of Appeals for the Second Circuit certified to the Court of Appeals a question regarding what deference a court should pay to an agency’s decision, made for its own enforcement purposes, to construe a statute prospectively only. In its amicus brief in the Court of Appeals, the Department asserted that no deference was due to it by the courts deciding the litigation. The Court of Appeals answered (1) courts should give an agency no more deference than it claims for itself; and (2) a party’s commitment to pay prevailing wages pursuant to the prevailing wage statute binds the party to comply with the statute as correctly interpreted, whether or not the correct interpretation was known to the parties at the time of contracting.View "Ramos v. SimplexGrinnell LP" on Justia Law

Lynn Becker contracted with the Ute Indian Tribe of the Uintah and Ouray Reservation (Tribe) to provide services related to the Tribe's development of its energy and mineral resources. Following a dispute concerning Becker's compensation under the contract, Becker brought breach of contract, breach of covenant of good faith and fair dealing, and accounting claims against the Tribe in the United States District Court for the District of Utah. All of Becker's claims were state law claims. Nevertheless, Becker's complaint asserted that the district court had federal question jurisdiction because the case raised substantial issues of federal law. Becker appealed the district court's dismissal of his complaint for lack of subject matter jurisdiction. Finding no reversible error, the Tenth Circuit affirmed.View "Becker v. Ute Indian Tribe of the Uintah" on Justia Law