Justia Contracts Opinion Summaries

Plaintiff, an in-home registered nurse, was injured in an automobile accident while driving her employer's vehicle to to a patient's home to perform her nursing duties. Plaintiff incurred $382,849 in medical expenses as a result of the accident. After Plaintiff's employer's workers compensation carrier (AIG) denied Plaintiff's workers compensation claim, Plaintiff filed a medical payments claim with Allstate, with whom Plaintiff had a personal automobile insurance policy that provided $100,000 in medical payments coverage. Allstate failed to provide medical payments benefits immediately to Plaintiff. Plaintiff and AIG later settled Plaintiff's worker's compensation claim for $150,000. Plaintiff then commenced this breach of contract and bad faith action against Allstate based on Allstate's failure to pay medical benefits. The circuit court granted judgment as a matter of law for $33,000 on the breach of contract claim and awarded $150,000 in compensatory damages and $1,500,000 in punitive damages on the bad faith claim. The Supreme Court reversed in part, holding that the circuit court erred in excluding Allstate's evidence of AIG's acceptance of the worker's compensation claim, and that exclusion prejudiced Allstate's ability to defend the bad faith and punitive damages claims. View "Bertelsen v. Allstate Ins. Co." on Justia Law

Plaintiff challenged the court's holding in Grochowski v. Phoenix Construction, which held that the Davis-Bacon Act, 40 U.S.C. 3141-3148, barred third-party private contract actions, brought under state law, aimed at enforcing the Act's prevailing wage schedules. The court concluded that Grochowski was the controlling law of this Circuit and foreclosed plaintiff's third-party beneficiary contract claim for failure to pay prevailing wages; the district court did not err in setting aside the jury's award of punitive damages under Federal Rule of Civil Procedure 50; the district court did not err in denying plaintiff's motion for a new trial as to damages on his discrimination claim; and, therefore, the judgment of the district court was affirmed. View "Carrion v. Agfa Construction, Inc." on Justia Law

Plaintiff brought a retaliatory discharge claim against her former employer (FedEx), alleging that she was terminated for exercising her rights as an injured worker pursuant to the Kansas Workers Compensation Act. Plaintiff filed her suit fifteen months after she was fired. FedEx responded by claiming that, while Kansas law provides a two-year statute of limitations of Plaintiff's claim, Plaintiff was bound by her employment contract to file her suit within six months of her termination. The federal district court granted summary judgment for FedEx. The federal court of appeals certified questions of Kansas law to the Kansas Supreme Court. The Supreme Court answered by holding that the private contract between FedEx and Plaintiff in this case violated public policy and was invalid to the extent it limited the applicable statute of limitations for filing a retaliatory discharge claim based on Plaintiff's exercise of her rights under the Workers Compensation Act. View "Pfeifer v. Federal Express Corp." on Justia Law

Plaintiff was terminated from his employment with Employer, ostensibly for his failure to properly investigate, document, and ameliorate the misconduct of an employee under his supervision. The termination occurred just months before Plaintiff was to receive a $60,000 bonus. Plaintiff filed an action against Employer to recover the bonus on the grounds that he was terminated without good cause. The U.S. district court granted summary judgment to Employer on Plaintiff's Massachusetts Wage Act claim and allowed Defendant's breach of contract claim to go to the jury. The jury found for Plaintiff. The First Circuit Court of Appeals (1) reversed the jury verdict, holding that whether Plaintiff was terminated without good cause and thus remained eligible for the bonus was a decision within the ambit of the sole and final decision-making authority of Employer's Employment Benefits Committee under the company's "Commitment to Success Bonus Plan"; and (2) affirmed the summary judgment order in Employer's favor, as Employer was under no obligation to pay the bonus. View "Weiss v. DHL Express, Inc." on Justia Law

Defendant Halliburton Energy Services hired Plaintiff Edward Flemma to work as a cement equipment operator in Houma, Louisiana, in January of 1982. During his twenty-six years of employment with Halliburton, Flemma was promoted several times and worked for the company in Louisiana, Texas, Angola, and New Mexico. The last position he held was as district manager in Farmington, New Mexico, where he worked from 2006 until the time of his termination in 2008.The issue on appeal before the Supreme Court in this case centered on a conflict of laws issue that requires the Court to determine whether enforcement of an arbitration agreement, formed in the State of Texas, would offend New Mexico public policy to overcome our traditional choice of law rule. Upon review, the Court concluded that the agreement formed in Texas would be unconscionable under New Mexico law, and it therefore violated New Mexico public policy. Thus, the Court applied New Mexico law and concluded that no valid agreement to arbitrate existed between the parties because Halliburton's promise to arbitrate was illusory. The Court reversed the Court of Appeals and remanded this case to the district court for further proceedings. View "Flemma v. Halliburton Energy Services, Inc." on Justia Law

The Supreme Court granted allocatur to determine whether the Superior Court erred by declining to validate a restrictive covenant contained in an employment agreement, solely because the restrictive covenant was not expressly referenced in an initial offer letter which conditioned employment on the execution of the employment agreement. Upon concluding the Superior Court did not properly characterize the offer letter, the Supreme Court vacated and remanded for further proceedings. View "Pulse Technologies v. Notaro" on Justia Law

Plaintiffs were individuals who lived in New York and worked there as couriers for Defendant, a corporation headquartered in Massachusetts. Plaintiffs brought this action in a Massachusetts court to enforce certain Massachusetts independent contractor, wage, and overtime pay statutes. The superior court dismissed the complaint, concluding (1) the Massachusetts independent contractor statute does not apply to non-Massachusetts residents working outside Massachusetts, and (2) as independent contractors, Plaintiffs failed to state claims under the Massachusetts wage statutes. The Supreme Court vacated the judgment of dismissal and remanded for further proceedings, holding that, insofar as the written contract between the parties contained an enforceable clause requiring both that actions be brought in Massachusetts and requiring that the contract and all rights and obligations of the parties be determined under Massachusetts law, and where application of Massachusetts law is not contrary to a fundamental policy of the jurisdiction where the individuals live and work, it was error to dismiss Plaintiffs' complaint. View "Taylor v. E. Connection Operating, Inc." on Justia Law

In 2005, the Department of Environmental Quality (DEQ) hired Plaintiff. In 2007, the DEQ terminated Plaintiff on the ground that he improperly incurred $2,500 in personal charges on a state-issued cell phone. Plaintiff challenged his termination, claiming the ground was pretext, and the Office of Administrative Hearings reinstated Plaintiff to his original position. The DEQ sought review of that position in district court and made an offer to settle, to which Plaintiff did not respond. The DEQ subsequently notified Plaintiff it was accepting his resignation because he had taken a job in Montana. The DEQ then withdrew its petition for review. In 2009, Plaintiff filed suit in federal district court, claiming the DEQ's failure to comply with the conditions of his proffered resignation constituted wrongful termination. The federal court dismissed the lawsuit. Plaintiff then filed suit in district court, alleging, inter alia, breach of contract and breach of the purported settlement agreement. The district court dismissed the case, ruling that Plaintiff's claims were time-barred. The Supreme Court dismissed Plaintiff's appeal for failure to follow the Wyoming Rules of Appellate Procedure. View "Armstrong v. Wyo. Dep't of Envtl. Quality" on Justia Law

Michael Holton appealed the grant of an interlocutory injunction prohibiting him from working in an executive capacity for a particular competitor of his former employer for one year. He also challenged the trial court's ruling that he would inevitably disclose his former employer's trade secrets and confidential information in violation of the trade secrets act and his confidentiality covenant if he went to work for the competing business. Because a stand-alone claim for the inevitable disclosure doctrine of trade secrets is not cognizable in Georgia, the Supreme Court reversed the part of the order enjoining Holton from the inevitable disclosure and use of trade secrets. On the remaining issues, the Court dismissed as moot his challenge to the order enjoining him from working for the competitor until October 2012 and affirmed the part of the order enforcing the confidentiality covenant. View "Holton v. Physician Oncology Services, LP" on Justia Law

After Employees separated from their employment with employer, Employer denied Employees' demand for payment of their unused "paid time off" (PTO) hours. The county court granted summary judgment for Employees, concluding that Employer was required to pay earned but unused PRO hours to Employees. The district court affirmed. At issue was whether Neb. Rev. Stat. 48-1229 of the Wage Payment and Collection Act (Act) entitled Employees to collect their unused PTO hours despite a provision in an employee manual that Employer would not pay them. The Supreme Court affirmed, holding that regardless of the label Employer attached to its PTO hours, they were indistinguishable from earned vacation time under section 48-1229, and like earned vacation time, Employees had an unconditional right to use their earned PTO hours for any purpose. View "Fisher v. PayFlex Sys. USA, Inc." on Justia Law