Justia Contracts Opinion Summaries

Plaintiff-hospital engaged Defendant to undertake demolition in a basement room at the hospital. Defendant hired brothers Luis and Gerardo Lema, undocumented aliens not legally employable in the United States. The Lemas were injured while performing the work and sued the hospital for violations of the state’s Labor Law. Supreme Court granted the Lemas summary judgment on liability. The hospital, meanwhile, brought this action for common-law and contractual contribution and indemnification against Defendant to recover damages incurred in the Labor Law litigation with the Lemas. Supreme Court granted Defendant’s motion to dismiss on the ground that the complaint did not state a cause of action, reasoning that N.Y. Workers’ Comp. Law 11 barred the hospital’s action. In so holding, the court determined that non-compliance with the Immigration Reform and Control Act (IRCA) did not deprive Defendant of the protection of section 11. The Appellate Division affirmed. The Court of Appeals affirmed, holding that Defendant was entitled to the safe harbor in section 11 because the Lemas did not suffer grave injuries, there was no preexisting agreement for contractual contribution or indemnification, and the hospital did not contend that IRCA preempts section 11. View "N.Y. Hosp. Med. Ctr. of Queens v Microtech Contracting Corp." on Justia Law

Plaintiff filed a complaint against his former employer and supervisors, alleging that he suffered discriminatory conduct while employed as a car salesman. Plaintiff asserted claims for state harassment and retaliation, federal harassment and retaliation, unlawful termination as against public policy, and breach of his employment contract. The circuit court granted summary judgment in favor of Defendants. The intermediate court of appeals (ICA) (1) vacated the grant of summary judgment in favor of the employer and one of Defendant’s supervisors on the state harassment and retaliation claims and vacated the grant of summary judgment in favor of the employer on the federal harassment and retaliation claims and the public policy claim, and (2) otherwise affirmed. The Supreme Court (1) vacated the ICA’s judgment on the state harassment and retaliation claims with respect to Plaintiff’s supervisor, holding that individual employees are not liable as employers under Haw. Rev. Stat. 378-2(1)(A) and 378-2(2); and (2) otherwise affirmed. View "Lales v. Wholesale Motors Co." on Justia Law

Retired Employees and their spouses filed suit against the County, alleging that the Retired Employees have an implied vested right to the pooling of their health care premiums with those of current employees ("pooled premiums"). The court affirmed the district court's order granting the County's motion for summary judgment, concluding that Retired Employees failed to raise a genuine issue of material fact where they did not show any link to Retired Employees' claim of an implied right to an ongoing pool premium; a practice or policy extended over a period of time did not translate into an implied contract without clear legislative intent to create that right - and intent that Retired Employees has not demonstrated in this case; Retired Employees' assertions that its involvement in negotiations with the County revealed an implied contract right to the pooled premium also lacked evidentiary support; and the nature of Retired Employees' evidence underscored the absence of any definitive intent or commitment on the part of the County to provide for the pooled premium. Accordingly, the court affirmed the district court's grant of the County's motion for summary judgment. View "REAOC v. County of Orange" on Justia Law

In 1999, Rick and Natalie Foeller entered into an agreement with Melaleuca of Canada, Inc., under which the Foellers would serve as independent marketing executives in exchange for monthly commission payments. In 2008, the Foellers breached this agreement but Melaleuca continued to pay them commissions because it was unaware of the breach. Upon learning of the breach, Melaleuca sued to recover the payments it had made to the Foellers after they breached. The district court granted Melaleuca’s motion for summary judgment, finding that under the forfeiture clause of its agreement with the Foellers, Melaleuca was simply excused from performing once the Foellers breached and ordered the Foellers to refund Melaleuca the commissions they received after their breach. The Foellers appealed, arguing that the district court erred because the forfeiture clause was an illegal penalty and Melaleuca was required to prove damages. Agreeing with the Foellers, the Supreme Court vacated the district court’s judgment and remanded the case for further proceedings. View "Melaleuca, Inc v. Foeller" on Justia Law

Plaintiff and her employer (Defendant) signed a document regarding the terms of Plaintiff’s employment. The parties agreed the document would cover "a thirty-six month period." After Defendant terminated Plaintiff’s employment before the term expired, Plaintiff filed suit, alleging that she and Defendant had entered into a letter agreement for a fixed term of employment of thirty-six months and that Defendant violated the agreement. The trial court concluded that, on its face, the letter agreement constituted a contract for a definite term and that Defendant breached the agreement when it terminated Plaintiff’s employment without good cause before the term expired. The appellate court affirmed. The Supreme Court reversed, holding that the letter agreement was ambiguous. Specifically, the language of the letter agreement could reasonably be interpreted as evincing either an intent to create a definite term of employment or an intent to set the terms and conditions of an at-will employment contract, and therefore, the trial court should have considered extrinsic evidence to determine the intent of the parties. Remanded for a new trial. View "Cruz v. Visual Perceptions, LLC" on Justia Law

In 1971 Milwaukee County provided its employees with health insurance under an ordinance that stated that the “county shall participate in the payment of monthly premiums” and extended coverage to retirees. In 1993, the ordinance was amended to provide that “[t]he County shall pay the full monthly cost of providing such [health insurance] coverage to retired members” as “part of an employee’s vested benefit contract.” Upon her 1991 retirement, Hussey had paid no co‐payments or deductibles for her health care. Her benefit plan booklet explained that with 15 years of service: “the retiree may participate in the health plan in which he/she is currently enrolled on the same basis as … the active employee group. The County will make the full premium contribution.” Until 2012, the plan coordinated benefits so that expenditures not covered by Medicare were paid in full by the County. In 2012 the County increased deductibles, co‐payments, and co‐insurance charges and modified coordination of benefits so that retirees over age 65 would pay the same deductibles, co‐payments, and co‐insurance charges as active employees. Hussey filed a purported class action, alleging that the failure to provide cost‐free health insurance to retirees constituted an unconstitutional taking of property. The Seventh Circuit agreed with the district court that the County only promised retirees the ability to participate in the same health insurance plan as active employees on a “premium‐free” basis.View "Hussey v. Milwaukee County" on Justia Law

Plaintiffs filed a putative collective action under the Fair Labor Standards Act, seeking backpay for time spent donning and doffing pieces of protective gear required by the employer because of hazards at its steel plants. The employer argued that the time, otherwise compensable under the Act, is noncompensable under its collective bargaining agreement with plaintiffs’ union. Under 29 U.S.C. 203(o), parties may collectively bargain over whether “time spent in changing clothes ... at the beginning or end of each workday” must be compensated. The district court granted the employer partial summary judgment. The Seventh Circuit and Supreme Court affirmed, concluding that the protective gear constitutes “clothes,” even if integral and indispensable to the work. Whether one exchanges street clothes for work clothes or simply layers one over the other may be a matter of purely personal choice, and section 203(o) should not be read to allow workers to opt into or out of its coverage at random or at will when another reading is textually permissible. Although safety glasses, earplugs, and a respirator do not fit the interpretation of “clothes,” the relevant question is whether the period at issue can, on the whole, be fairly characterized as “time spent in changing clothes or washing.” In this case, time spent donning and doffing safety glasses and earplugs was minimal. View "Sandifer v. United States Steel Corp." on Justia Law

In the 1990s, Defendants (Employers) created a sick-leave policy allowing employees to bank their sick leave in a continued illness bank (CIB). In 2002, Employers modified the terms of the CIB to create the CIB pay-out benefit, which allowed a capped amount of unused CIB hours to be paid to departing employees who completed twenty-five years or more of service. In 2008, Employers terminated the CIB pay-out benefit, and only employees who had reached twenty-five years of employment with Employers were entitled to their earned but unused CIB hours upon termination. Plaintiffs in this case represented employees who had not reached twenty-five years of service before the benefit ended. Plaintiffs brought a class action complaint against Employers. The district court granted summary judgment for Employers. The Supreme Court affirmed, holding that the district court did not err in determining that (1) Employers’ policies did not constitute a standardized group employment contract; (2) the CIB pay-out benefit was not deferred compensation or wages under the Montana Wage and Wage Protection Act; and (3) the covenant of good faith and fair dealing did not apply to Plaintiffs’ claims. View "Chipman v. Northwest Healthcare Corp." on Justia Law

Plaintiff appealed the district court's dismissal of his discrimination claim against his former employer under Rule 12(b)(3) for improper venue. Defendants moved to dismiss on the basis of a clause contained in plaintiff's employment contract, which indicated that English law governed the agreement and that "any dispute arising hereunder shall be subject to the exclusive jurisdiction of the English courts." The court affirmed, holding that where a contract contained both a valid choice-of-law clause and a forum selection clause, the substantive law identified in the choice-of-law clause governed the interpretation of the forum selection clause, while federal law governed the enforceability of the forum selection clause; under English law, plaintiff's discrimination claims arose under the employment agreement, within the meaning of the forum selection clause; and the forum selection clause was enforceable under federal law. Accordingly, the court affirmed the judgment of the district court. View "Martinez v. Bloomberg LP" on Justia Law

Respondents filed a complaint for accounting against Petitioner, their employer, after a dispute over the terms of their employment agreement. In response, Petitioner filed a petition to compel arbitration, asserting that, because Respondents’ claims arose out of their employment agreements, the circuit court was required to compel arbitration under an arbitration clause contained in the employment agreement. The circuit court denied Petitioner’s petition. The intermediate appellate court dismissed Petitioner's appeal, concluding that the denial of Petitioner’s motion to compel arbitration did not constitute a final judgment. The Supreme Court affirmed, holding that an order denying a request to compel arbitration filed in an existing action is not a final judgment because the denial of the petition does not put the parties out of court or otherwise terminate the proceedings and does not deny the party requesting arbitration the means of further prosecuting or defending rights and interests in the subject matter of the proceeding. View "Am. Bank Holdings, Inc. v. Kavanaugh" on Justia Law