Justia Contracts Opinion Summaries

Articles Posted in Labor & Employment Law
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This case involved an employment dispute between Defendant, a home heating oil company, and Plaintiffs, two former delivery truck drivers. Plaintiffs argued that they were owed compensation based on their classification as employees, rather than as independent contractors, under the Wage Act. Defendant responded (1) Plaintiffs' claims were barred by the statute of limitations, and (2) alternatively, a general release contained in the parties' contract termination agreements nevertheless defeated the Wage Act claims. The superior court stayed the proceedings and reported the statute of limitations and general release issues to the appeals court. The Supreme Court transferred the case on its own motion and held (1) Plaintiffs were entitled to recover for damages that occurred within the three-year period prior to filing the complaint; (2) the general releases contained in the contract carrier termination agreements that did not explicitly include the release of Wage Act claims failed to waive those claims; and (3) as a result, Plaintiffs remained entitled to recover for their damages accruing within the three-year period prior to filing the lawsuit. View "Crocker v.Townsend Oil Co." on Justia Law

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The plaintiff-appellants, Bruce Bermel and Pamela Jurga, as husband and wife, appealed the final judgment of the Superior Court granting the motion for summary judgment of the defendant-appellee, Liberty Mutual Fire Insurance Company. The appellants contended that the Superior Court erred by granting summary judgment in favor of Liberty. Bermel was injured in an automobile accident when his personal motorcycle was struck head-on by another driver. Bermel, then an employee of the Siemens Corporation, contended that the business policy issued to Siemens by Liberty on a company car that was assigned for his business and personal use, provided him with $100,000 in underinsured motorist coverage even when he was operating a non-work vehicle in circumstances unrelated to his employment. Bermel brought this action for underinsured benefits (“UIM”) against Liberty arguing: (1) that the Liberty Policy covering the company car he used was personal to him, even though Siemens was the named insured; (2) that he was entitled to personally access the Liberty Policy because Siemens automatically deducted a nominal fee from his paycheck for his personal use of the vehicle assigned to him that was insured by the Liberty Policy; and (3) that the Liberty Policy was ambiguously drafted and should have been construed in his favor. Upon review, the Supreme Court concluded that the Superior Court correctly found Siemens, and not Bermel, to be the named insured on the Liberty Policy, that the nominal fee charged to Bermel by Siemens for the use of the car did not make Bermel a named insured under the Liberty Policy, and that the Liberty Policy was unambiguous. Therefore, the judgments of the Superior Court were affirmed. View "Bermel v. Liberty Mutual Fire Insurance Co." on Justia Law

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A collective-bargaining agreement between Baltimore County and Baltimore County Fraternal Order of Police, Lodge 4 (FOP) contained an arbitration clause and a retiree health-insurance provision. FOP believed the provision locked in place the health-insurance subsidy as it existed at the time of an officer's retirement. After the agreement expired and the County decreased the health-insurance subsidy, FOP initiated arbitration. The County protested, arguing (1) it had no duty to arbitrate because the collective-bargaining agreement had expired, and (2) the health-insurance subsidy was not locked in place but was subject to change from year to year. FOP was successful in arbitration and on appeal before the circuit court, but the court of special appeals vacated the arbitration award. The Court of Appeals reversed, holding (1) an arbitration clause may survive the expiration of a collective bargaining agreement when it concerns rights that vested during the life of the agreement; and (2) when deciding the issue of arbitrability requires interpretation of the underlying agreement and consideration of the merits of the dispute, the issue of arbitrability should initially be determined by the arbitrator. View "Baltimore County Fraternal Order of Police Lodge v. Baltimore County" on Justia Law

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An encounter between a tenured professor at a private university and his department head turned into a formal complaint of harassment against the professor. After extensive internal proceedings, the professor's tenure was rescinded and he was dismissed from the university's faculty. The professor filed suit claiming breach of his employment contract and tenure agreement. The trial court granted summary judgment in favor of the university. The Supreme Court affirmed the decision of the trial court, holding (1) the professor's conduct constituted harassment under the terms of his employment contract such that the university could dismiss him; (2) the university did not deny the professor the procedural entitlements afforded under the professor's employment contract's terms; and (3) the university did not deprive the professor of due process. View "Haegert v. Univ. of Evansville" on Justia Law

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Under the terms of a collective-bargaining agreement, the City of Newport provided health insurance benefits to its retired firefighters. After the City decided to modify those benefits, Local 1080, International Association of Firefighters, ALF-CIO (Union) filed grievances and sought arbitration. The City responded by seeking relief in the superior court to determine the arbitrability of disputes over changes to these benefits. The superior court determined that this dispute was not arbitrable. The Union disagreed and petitioned the Supreme Court for a writ of certiorari. The Court affirmed the judgment of the superior court, holding that the parties did not intend to arbitrate disputes regarding retiree healthcare, and therefore, such disputes must be resolved, if at all, judicially rather than through arbitration. View "City of Newport v. Local 1080, Int'l Ass'n of Firefighters, AFL-CIO" on Justia Law

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Plaintiff was severely injured in a workplace accident and sued Trail King, the custom manufacturer of the trailer involved in the accident. The First Circuit Court of Appeals affirmed a jury's finding that Defendant had not been negligent nor in breach of any warranty. In the trial court in that diversity case, Plaintiffs belatedly attempted to amend their complaint to add another claim, one under Mass. Gen. Laws ch. 93A for unfair and deceptive trade practices. The trial judge denied the motion, finding the effort to amend untimely. Plaintiffs did not appeal this denial in their earlier appeal. This case concerned whether Plaintiffs may now maintain an independent suit for the ch. 93A claims against Trail King. The district court dismissed the claims with prejudice, finding that the doctrine of claim preclusion applied. Plaintiffs appealed, arguing that ch. 93A, 9(8) provides an exception to the normal rules of res judicata. The First Circuit affirmed, holding that under the facts of this case, Plaintiffs may not now bring this ch. 93A claim because of the failure to appeal from the denial of the motion to amend. View "Hatch v. Trail King Indus., Inc." on Justia Law

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Norman Budge and twenty-eight additional parties (collectively, Employees) filed a complaint for review of government action for the Town of Millinocket's (Town) amendments to its personnel policy originally adopted as a town ordinance. In the most recent amendment, the Town reduced its obligation for paying for the health insurance plan for its employees and established a new policy for the health insurance offered to retirees that resulted in the Town reducing its payment of the retirees' premiums. Employees alleged that, regardless of the policy language, this reduction was inconsistent with promises made to them either when they were hired or during their tenure with the Town. The superior court granted summary judgment in favor of the Town. The Supreme Court affirmed, holding (1) the personnel policy did not create an enforceable contract between the Town and its employees; (2) the Town was not bound to pay Employees' retirement group hospitalization and life insurance premiums by virtue of promissory estoppel; and (3) the Town's reduction in benefits did not result in an unconstitutional taking. View "Budge v. Town of Millinocket" on Justia Law

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Plaintiffs brought suit against Defendant, the Cranston School Department, seeking grievance arbitration of adverse actions taken against them as to their respective coaching positions at Cranston West High School. Plaintiffs, both of whom were teachers at Cranston West, separately filed grievances against Defendant in accordance with the collective bargaining agreement (CBA) that was in place between the Cranston Teacher's Alliance and the school department. Defendant responded that the CBA did not apply to Plaintiffs in their capacity as coaches, and it refused to submit to arbitration. Plaintiffs filed suit, seeking a declaratory judgment that they were entitled to binding arbitration as guaranteed by the CBA. The superior court ruled in favor of Defendant, determining that Plaintiffs, in their capacity as coaches, were not entitled to avail themselves of the CBA's grievance procedures. The Supreme Court affirmed, holding (1) the trial justice was correct in determining that Plaintiffs' coaching positions were contractually distinct from their teaching positions and did not constitute professional employment; and (2) Plaintiffs in their coaching capacities had no right to pursue relief based on the rights bargained for by the alliance on behalf of its teacher-members and as contained in the CBA. View "Sacco v. Cranston Sch. Dep't" on Justia Law

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This matter was before the Supreme Court on a motion for reconsideration filed by Appellant, Acordia of Ohio, LLC (the LLC). The Supreme Court granted the motion. In Acordia I, the Court affirmed the judgment of the court of appeals, concluding that while the noncompete agreements of employees (Appellees), who were originally employed by a contracting employer, transferred by operation of law following merger with the LLC, the language found in those agreements precluded the LLC from enforcing them as if it had stepped into the shoes of the original contracting employer. Upon reconsideration, the Supreme Court reversed the court of appeals, holding (1) the language in Acordia I stating that the LLC could not enforce the employees noncompete agreements as if it had stepped into the original contracting company's shoes was erroneous; and (2) the LLC here may enforce the noncompete agreements as if it had stepped into the shoes of the original contracting companies, provided that the noncompete agreements are reasonable under the circumstances of this case. View "Acordia of Ohio, LLC v. Fishel" on Justia Law

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This dispute arose out of an employment contract between defendant and plaintiffs, his employer. After receiving a favorable judgment in a prior proceeding, defendant moved to dismiss plaintiffs' complaint in the present action on the basis of res judicata. Defendant also filed a motion requesting sanctions and attorney's fees. The district court granted the motion to dismiss but declined to impose sanctions or award attorney's fees. Both parties appealed. The court concluded that the district court properly decided the merits of defendant's res judicata defense on a motion to dismiss. On the merits, Count VI was barred by res judicata where the cause of action existed at the time of the first judgment and it occurred from the same transaction or occurrence. Finally, the court affirmed the district court's decision to deny sanctions and attorney's fees. View "C.H. Robinson Worldwide, Inc., et al v. Lobrano, Jr." on Justia Law