Justia Contracts Opinion Summaries

In 1998, Jerry Lee Baldwin entered into a written agreement with the Board of Supervisors for the University of Louisiana System to serve as the head football coach at the University of Southwestern Louisiana, now University of Louisiana at Lafayette (UL). The contract provided that Baldwin’s employment with UL would last until January 31, 2003. By letter dated November 27, 2001, Baldwin was “relieved of [his] duties” as UL’s head coach effective November 26, 2001, after winning only six of twenty-seven games (an 18% win record). Baldwin continued to receive his full monthly salary and other employee benefits from UL including health insurance, accrual of leave time, and accrual of retirement credits for the remainder of the contract term. Baldwin sued the Board over the contract. Defendants sought review of the court of appeal’s determination that the coach’s contract had been terminated, which triggered a contractual obligation to provide notice. Interpreting the contract in its entirety, the Supreme Court found that the appellate court erred in finding that the failure of notice constituted a breach of contract under the facts of this case. Accordingly, the Court reversed the appellate court’s decision and reinstated the summary judgment rendered by the trial court, which dismissed the coach’s breach of contract claim against defendants.View "Baldwin v. Board of Supervisors for the University of Louisiana System" on Justia Law

After Sining Mao left his employment with Seagate Technology, LLC, Mao joined Seagate’s competitor, Western Digital Corporation. Seagate subsequently commenced a district court action alleging that Mao stole Seagate’s trade secrets and confidential information and provided it to Western Digital. Western Digital invoked an arbitration clause in Mao’s employment agreement with Seagate. Before the arbitration hearing, Seagate brought a motion for sanctions against Western Digital and Mao (Appellants) based on alleged fabrication of evidence. An arbitrator issued an award against Appellants in an amount exceeding $500 million. The district court vacated the award in part, but the court of appeals reinstated the award. On appeal, Appellants argued that the arbitrator’s exceeded his authority by issuing punitive sanctions and prejudiced Appellants by refusing to hear evidence material to the controversy. The Supreme Court affirmed the court of appeals’ decision reinstating and confirming the arbitration award in full, holding that the arbitrator did not exceed his authority or refuse to hear material evidence as required for vacatur.View "Seagate Tech., LLC v. W. Digital Corp." on Justia Law

Washington Group, an engineering, construction and management services company, offered Abraham a position as a “lead scheduler” for a project in Wisconsin. After negotiations, Washington Group sent Abraham a letter offering him the title of “project control manager,” a higher position higher in the chain of command. Abraham, who worked for the company for about a year, pursuant to his written contract before leaving the company and filing suit, claimed that Washington Group and its parent, URS, also promised him that he would perform the duties of a project control manager and then breached that promise. The defendants claim that Abraham understood that it would give him the title of project control manager for purposes of increasing his salary but he would perform the functions of a lead scheduler on a day-to-day basis. The district court entered summary judgment for the defendants. The Seventh Circuit affirmed, stating that Abraham received all of the promises set forth in his unambiguous written contract.View "Abraham v. Washington Grp. Int'l, Inc." on Justia Law

Plaintiff appealed the district court's grant of summary judgment in favor of his former employers, BoA, on his claim of age discrimination under the Age Discrimination in Employment Act of 1967 (ADEA), 29 U.S.C. 621 et seq., and breach of contract. Under the McDonald Douglas Corp v. Green framework, assuming arguendo that plaintiff met his burden of demonstrating a prima facie case of age discrimination, the court agreed with the district court that BoA has satisfied its burden to articulate a legitimate, nondiscriminatory reason for plaintiff's termination. BoA has explained that plaintiff's employment was terminated as part of a company-wide reduction in force; two months prior to his termination, plaintiff received a negative mid-year performance review; and as of September 2010, plaintiff was ranked 136th across all BoA sales personnel for the year and his performance was the worse of all employees in his group. In regards to the breach of contract claim, the district court correctly determined that plaintiff was an at-will employee and that although annual bonuses were discretionary, there is no record evidence, or even an allegation, indicating that plaintiff was promised a mid-year bonus. Accordingly, the court affirmed the judgment of the district court.View "Delaney v. Bank of America Corp." on Justia Law

McCarthy worked at Ameritech, a wholly owned subsidiary of AT&T, until her position was terminated in 2008 as part of a reduction in forces. She sought to retire at that time to care for her ailing husband, but Ameritech allegedly told her that she was not eligible to receive post-retirement healthcare benefits, on which her husband depended. She elected to continue working through the company’s Employment Opportunity Pool for another nine months, until she turned 65 and retired with benefits. She then filed suit alleging, among other things, age and sex discrimination. After Ameritech admitted that McCarthy was, in fact, entitled to post-retirement healthcare benefits when it terminated her position in 2008, she amended her suit to add a claim for fraudulent inducement. The district court awarded summary judgment, rejecting the merits of each claim. The Sixth Circuit reversed in part. McCarthy may present her fraudulent-inducement claim to a jury. The district court properly awarded summary judgment to the defendants on each of the other claims View "McCarthy v. Ameritech Publ'g, Inc." on Justia Law

Plaintiffs, active and retired Baltimore police officers and firefighters who participate in a public pension plan, challenged the City's decision changing the manner in which annual increases to pension benefits are calculated. Plaintiffs claimed that the substitution of a cost-of-living adjustment for a "variable benefit" violates the members' rights under the Contract Clause and the Takings Clause. The court concluded that the members' rights under the Contract Clause were not impaired because the members retained a state law remedy for breach of contract. Accordingly, the court vacated the district court's judgment with respect to the City's elimination of the variable benefit. The court affirmed the district court's decision upholding the remaining portions of the ordinance at issue, and vacated the district court's order dismissing the Takings Clause claim. The court remanded for further proceedings. View "Cherry, Jr. v. Mayor and City Council of Baltimore City" on Justia Law

Beginning in 1974, Douglas County’s retired employees paid the same amount as active employees for health insurance coverage. In 2009, the County Board of Commissioners adopted a resolution that charged retirees premiums that were higher than the rate paid by active employees. Shortly before the change was to take effect, retired employees of the County (Plaintiffs) sued the County. The district court entered judgment in favor of Plaintiffs, concluding that equitable estoppel prohibited the County from increasing the premiums to be paid by the retirees above those paid by active employees. The Supreme Court reversed, holding that because the retirees had no contractual right to pay the same premiums as active employees, the district court erred in using equitable estoppel to create such a contractual obligation. Remanded with direction to enter judgment for the County on Plaintiffs’ claims. View "Christiansen v. County of Douglas" on Justia Law

Lisa Knitter worked as a "handyman" for Lewis General Contracting, Inc. (LGC) from March to October 2010. During this time, LGC's sole client was Picerne Military Housing, LLC (Picerne), now known as Corvias Military Living, LLC. Knitter performed handyman services exclusively on Picerne properties. She sued Picerne under Title VII of the Civil Rights Act of 1964, alleging: (1) she was paid lower wages than her male counterparts; (2) Picerne effectively fired her in retaliation for her complaints of sexual harassment and wage discrimination; and (3) after she was fired, Picerne denied her application for vendor status in retaliation for her prior complaints of discrimination. The district court granted summary judgment to Picerne, dismissing Knitter's Title VII action because Picerne was not her employer. The district court also dismissed her claim for retaliatory denial of vendor status because Knitter did not apply for employment with Picerne when she applied to be a vendor. Knitter appealed to the Tenth Circuit Court of Appeals. Finding no reversible error, however, the Tenth Circuit affirmed. View "Knitter v. Picerne Military Housing" on Justia Law

Plaintiff filed a class action suit to recover unpaid overtime wages from her former employer, Bloomingdale's. The district court granted Bloomingdale's motion to compel arbitration, determining that shortly after being hired by Bloomingdale's, plaintiff entered into a valid, written arbitration agreement and that all of her claims fell within the scope of that agreement. The court concluded that plaintiff had the right to opt out of the arbitration agreement, and had she done so she would be free to pursue this class action in court. Having freely elected to arbitrate employment-related disputes on an individual basis, without interference from Bloomingdale's, she could not claim that enforcement of the agreement violated either the Norris-LaGuardia Act, 29 U.S.C. 101 et seq., or the National Labor Relations Act, 29 U.S.C. 151 et seq. The court concluded that the district court correctly held that the arbitration agreement was valid and, under the Federal Arbitration Act, 9 U.S.C. 1 et seq., it must be enforced according to its terms. The court affirmed the judgment of the district court. View "Johnmohammadi v. Bloomingdale's, Inc." on Justia Law

Plaintiff filed a class action suit alleging that Nordstrom violated various state and federal employment laws by precluding employees from bringing most class action lawsuits in light of AT&T Mobility LLC v. Concepcion. Nordstrom, relying on the revised arbitration policy in its employee handbook, sought to compel plaintiff to submit to individual arbitration of her claims. The district court denied Nordstrom's motion to compel. The court concluded that Nordstrom satisfied the minimal requirements under California law for providing employees with reasonable notice of a change to its employee handbook, and Nordstrom was not bound to inform plaintiff that her continued employment after receiving the letter constituted acceptance of new terms of employment. Accordingly, the court concluded that Nordstrom and plaintiff entered into a valid agreement to arbitrate disputes on an individual basis. The court reversed and remanded for the district court to address the issue of unconscionably. View "Davis v. Nordstorm, Inc." on Justia Law