Justia Contracts Opinion Summaries
Articles Posted in Labor & Employment Law
Armstrong v. Wyo. Dep’t of Envtl. Quality
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
Holton v. Physician Oncology Services, LP
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
Fisher v. PayFlex Sys. USA, Inc.
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
Liberty Mutual Insurance Company v. Shoemake
The issue before the Supreme Court in this case concerned the proper procedure by which a workers' compensation insurer may enforce a subrogation claim arising under Mississippi Code Section 71-3-71. Richard Shoemake was injured in Alabama but received workers' compensation benefits from Liberty Mutual Insurance Company under Mississippi law. He brought and settled a third-party action in Alabama state court and reimbursed Liberty Mutual only the amount it was entitled to under Alabama law. Liberty Mutual, which knew of but did not join or intervene in the Alabama lawsuit, then sued Shoemake in the Circuit Court of Newton County, seeking full reimbursement as allowed under Section 71-3-71. In granting Shoemake summary judgment, the circuit court held that Alabama law applied and further concluded that res judicata and Liberty Mutual's failure to intervene in the Alabama action barred Liberty Mutual's claim. The Court of Appeals reversed, holding that Mississippi law governed the amount of Liberty Mutual's subrogation claim and that Liberty Mutual was not required to intervene in the Alabama action to become entitled to reimbursement under Mississippi law. Because the Mississippi Supreme Court found that 71-3-71 requires a workers' compensation insurer to join or intervene in a third-party action to become entitled to reimbursement, it reversed the Court of Appeals and affirmed the circuit court. View "Liberty Mutual Insurance Company v. Shoemake" on Justia Law
Harleysville Ins. Co. v. Physical Distrib. Serv., et al
This case involved the interpretation of two contractual provisions under Minnesota law: an indemnification clause in a contract between PDSI and Miller and an insurance contract between Harleysville and PDSI which extended insurance coverage to PDSI's indemnification of third parties for tort liability caused, in whole or in part, by PDSI or by those acting on its behalf. The court agreed with the district court's finding that a PDSI employee's suit fell squarely within the indemnity provision of the 1989 Agreement between PDSI and Miller. The court also agreed with the district court's interpretation of the insurance agreements as requiring Harleysville to cover Miller's settlement of the employee's claims. Further, the court concluded that the undisputed facts established as a matter of law that PDSI or those acting on its behalf at least partly caused the employee's bodily injury within the terms of the Harleysville policy. Accordingly, the court affirmed the judgment. View "Harleysville Ins. Co. v. Physical Distrib. Serv., et al" on Justia Law
Petersen v. Boeing Co.
Plaintiff brought suit against Boeing and BISS alleging breach of contract as well as several statutory and common law claims. At issue was the enforceability of a forum selection clause. The court held that the evidence submitted and the allegations made by plaintiff were more than sufficient to create a triable issue of fact as to whether the forum selection clause at issue here was enforceable under M/S Bremen v. Zapata Off-Shores Co. Therefore, the district court abused its discretion by granting BISS's motion to dismiss without convening an evidentiary hearing. The district court also abused its discretion in denying plaintiff leave to amend his pleadings. Accordingly, the court reversed and remanded. The court did, however, grant Boeing's and BISS's joint motion to strike the portions of plaintiff's reply brief that included new evidence or alleged new facts not in the record before the district court. View "Petersen v. Boeing Co." on Justia Law
Ky. Uninsured Employers’ Fund v. Hoskins
Employee sustained injuries in the course of his employment with Four Star Transportation. Despite being hired by Four Star, Employee was initially considered an employee of Better Integrated Services. Better Integrated leased Employee to Beacon Enterprises, which then leased Employee to Four Star. Beacon had an insurance policy with Kentucky Employers' Mutual Insurance (KEMI). An ALJ determined (1) Employee's injury entitled him to benefits and a permanent partial disability award, and (2) KEMI's policy covered Employee's injury. The Workers' Compensation Board reversed, finding Employee was not covered under the KEMI policy due to the fact he was unaware that Four Star was leasing him from different entities, including Beacon. The court of appeals affirmed. The Uninsured Employers' Fund appealed. The Supreme Court affirmed, holding (1) Employee could not be considered Beacon's employee because he did not enter into a contract for hire with Beacon; (2) the Board did not act arbitrarily in finding that the ALJ's opinion was not supported by substantial evidence; and (3) the Board and lower court's decision was not based on Better Integrated and Beacon's failure to comply with Ky. Rev. Stat. 342.615. View "Ky. Uninsured Employers' Fund v. Hoskins" on Justia Law
Longaker v. Boston Scientific Corp., et al
Plaintiff appealed the district court's dismissal of his breach of contract and retaliation claim against Boston Scientific. Plaintiff filed for Chapter 7 bankruptcy and then Boston Scientific terminated his employment shortly after his filing. The court concluded that, because the guaranteed payments at issue, if due at all, were property of the bankruptcy estate, plaintiff lacked standing to assert his breach of contract claim. Plaintiff's argument that had Boston Scientific not terminated him, the payments he received under the Employment Agreement would have been future earnings also failed. Because plaintiff never requested leave to amend his complaint to include a retaliation claim, the district court could not be faulted for failing to allow him to do so. Accordingly, the court affirmed the judgment. View "Longaker v. Boston Scientific Corp., et al" on Justia Law
McLemore v. Weiss
Appellants, state police officers, brought this suit individually and on behalf of a class consisting of members of the Arkansas State Police Retirement System (ASPRS), contending that various state defendants had violated the law by failing to properly fund the ASPRS between 1992 and 2003 and that the improper funding violated the Arkansas Constitution. The circuit court dismissed some of Appellants' claims and remanded. On remand, the circuit court granted summary judgment for Defendants. On appeal, Appellants asserted that the circuit court erred in finding that a uniform and travel-expense allowance provided for in Ark. Code Ann. 12-8-209 was not reportable to the ASPRS as a portion of payroll pursuant to Ark. Code Ann. 24-6-209(a). The Supreme Court affirmed, holding that section 24-6-209(a) does not include a uniform and travel-expense allowance such that it is reportable to ASPRS for purposes of calculating retirement benefits. View "McLemore v. Weiss" on Justia Law
Rios-Pineiro v. United States
The United States Postal Services (USPS) terminated Plaintiff's employment contract after discovering, through a sting operation, that Plaintiff had stolen mail containing money. The Postal Service Board of Contract Appeals (PSBCA) convened an evidentiary hearing and determined that Plaintiff's breach of his employment contract justified the decision to terminate his contract. Plaintiff did not appeal this decision. Meanwhile, Plaintiff initiated a Federal Tort Claims Act (FTCA) suit against the United States for the actions of USPS employees on the date of the sting, alleging six torts. The district court dismissed three of the claims and granted summary judgment to the government on the remaining claims. The First Circuit Court of Appeals affirmed the district court as to all claims, holding (1) the district court correctly concluded that the PSCBA's findings precluded relitigation of the factual issues in Plaintiff's FTCA suit; and (2) summary judgment was properly granted as to Plaintiff's FTCA claims for negligent supervision, malicious prosecution, and invasion of privacy by postal inspectors. View "Rios-Pineiro v. United States" on Justia Law