Justia Contracts Opinion Summaries

At issue in this case was whether the workers' compensation courts had the authority to hear a petition filed by Insured to determine whether Insurer had a duty to defend and indemnify Insured under a policy for workers' compensation insurance. Insurer moved to dismiss Insured's petition, arguing that the compensation judge did not have subject matter jurisdiction to hear the petition because it asserted a breach of contract claim rather than one arising under the workers' compensation laws. The compensation judge disagreed and denied Insurer's motion to dismiss. The workers' compensation court of appeals (WCCA) affirmed, concluding that Insured was seeking a declaration that its insurance coverage with Insurer was still "in effect," a question within the compensation judge's authority to decide. The Supreme Court affirmed, holding that the workers' compensation courts had jurisdiction to decide the issues presented in Insured's petition for declaration of insurance coverage, as the real nature of the claim was whether Insured's insurance coverage was in effect, a question that was within the authority of the compensation judge to answer. View "Giersdorf v. A & M Constr., Inc." on Justia Law

Trinity terminated Dr. Assaf’s employment in 2009t. Assaf filed suit for breach of contract. While the case was pending, Assaf negotiated with Trinity’s new CEO, Tibbitts, Apparently without attorneys, Assaf and Tibbitts signed an agreement that provided that Assaf would receive a salary of $50,000 each year from 2009 to 2011. After that, his employment would automatically renew for a year unless either party gave notice of termination. Trinity refused to honor the agreement. The district court decided to enforce the agreement, but granted Trinity’s motion to bar any evidence of Assaf’s lost professional fees. Trinity never re-employed Assaf, claiming that “there is a policy against ordering specific performance of a personal services contract.” The court ordered Trinity to reinstate Assaf. Rather than reinstating Assaf, Trinity filed a “motion to clarify or stay.” The court reversed its earlier order, proceeded, without trial, to award Assaf his salary for the years 2009 through 2011, attorney’s fees, and compensatory damages. The court did not award any amount in lost professional fees. The Seventh Circuit reversed, declining to address specific performance because Trinity properly reterminated Assaf in 2011. The district court abused its discretion in barring evidence of lost professional fees. View "Assaf v. Trinity Med. Ctr." on Justia Law

The issue in this case was whether an appellate court has jurisdiction over an appeal from a trial court order confirming an arbitration award in part and vacating the award in part based on the existence of unresolved questions of law or fact necessary to a ruling, yet the trial court did not expressly direct a rehearing. The court of appeals held that it did not have jurisdiction over the appeal, holding (1) the judgment was not final because it did not contain finality language or otherwise state that it was a final judgment and necessarily contemplated resolution of the remaining issues by way of a rehearing, and therefore, the appeal was interlocutory; and (2) no statute permitted an appeal in this case. The Supreme Court affirmed and, for different reasons, dismissed the appeal for want of jurisdiction, holding (1) the appeal was interlocutory; (2) the Texas Arbitration Act did not provide jurisdiction over the interlocutory appeal; and (3) there is no jurisdiction over arbitration awards that are incomplete unless, under certain circumstances, the parties file a writ of mandamus, which neither party here filed. View "Bison Bldg. Materials, Ltd. v. Aldridge" on Justia Law

Plaintiff brought suit against Seagate, alleging a violation of Minnesota Statutes section 181.64, false statements as inducement to entering employment, and a common law claim of promissory estoppel. On appeal, Seagate argued, among other things, that the district court submitted an erroneous jury instruction. Plaintiff cross-appealed, arguing that if a new trial was ordered on the statutory claim, his promissory estoppel claim should likewise be retried. The court concluded that the district court erred in instructing the jury, and thus the court reversed. The court vacated the order dismissing the promissory estoppel claim and remanded for a new trial on both claims. The court also vacated the order granting attorneys' fees. View "Vaidyanathan v. Seagate US LLC, et al." on Justia Law

This case involved a claim by a former professional football player (the athlete) for benefits under the Maryland Workers' Compensation Act based on an injury during pre-game warm-up at the employer's stadium in Maryland. The employment agreement contained a forum selection clause providing, inter alia, that claims for workers' compensation benefits should be governed by Virginia law and that the Virginia Workers' Compensation Commission should have exclusive jurisdiction to resolve such claims. The Maryland Workers' Compensation Commission decided that it could properly exercise jurisdiction over the athlete's claim, that the athlete had sustained an accidental injury arising out of the course of his employment, and that the athlete's disability was causally related to his accidental injury. The circuit court upheld the decision. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) the forum selection clause in the employment contract was ineffective to divest the Commission of the ability to exercise jurisdiction; and (2) injuries occurring while playing and practicing professional football are accidental injuries and thus compensable under the Act. View "Pro-Football, Inc. v. Tupa" on Justia Law

David Fesler, a former sales representative with Whelen Engineering Company, sued Whelen for breach of contract. Fesler alleging that he was an employee of Whelen, that policy documents issued by Whelen applicable to sales representatives created a unilateral contract of employment, and that Whelen breached that unilateral contract of employment by terminating him without just cause and by failing to provide him with notice of substandard performance and an opportunity to cure. The district court granted summary judgment for Whelen. The Eighth Circuit Court of Appeals affirmed, holding that because Fesler was an independent contractor and not an employee, the policy documents could not have created a unilateral contract. Thus, the district court properly dismissed Fesler's claim for breach of contract. View "Fesler v. Whelen Eng'g Co." on Justia Law

Whelan Security Company appealed a trial court's grant of summary judgment in favor of Charles Kennebrew and W. Landon Morgan on its action to enforce the non-compete agreements it had with Kennebrew and Morgan. On appeal, Whelan claimed that the trial court erred in concluding that the non-competition and non-solicitation clauses were invalid as overbroad and unreasonable as to time and space. The Supreme Court granted transfer and reversed, holding that the non-compete agreements were unreasonable as written but modified the terms of the agreements to give effect to the intent of the parties in entering the non-compete agreement; and (2) because genuine factual issues existed, entry of summary judgment was improper. Remanded. View "Whelan Security Co. v. Kennebrew" on Justia Law

Whiteman was employed by the FAA and reported violations of regulations, mismanagement, and abuses of authority. Whiteman alleged that colleagues and supervisors began to threaten and intimidate her. She filed EEO actions and reported one incident to police. She was excluded from the radar room and stripped of duties, then reassigned to the control tower instead of her previous job. In 2003, Whiteman settled with the FAA resolving all claims, “known or unknown” in exchange for guaranteed priority consideration for the next available supervisor position. December 9, 2003, Whiteman applied for a position. No other applicants were considered. December 18, 2003, the FAA adopted pay scale changes, which reduced the salary of the position. Whiteman accepted the position, but sued, alleging that the FAA’s delay in notifying her of the vacancy breached the settlement agreement and caused loss of earnings. The district court dismissed for lack of subject matter jurisdiction. Whiteman appealed to the Merit Systems Protection Board contending that the FAA had unlawfully retaliated against her for whistleblowing. The Board concluded that the claim was barred. The Federal Circuit affirmed in part. The MSPB incorrectly concluded that Whiteman’s post-settlement retaliation claim was collaterally estopped, but its conclusion that the settlement agreement is enforceable is supported by substantial evidence. View "Whiteman v. Dep't of Transp." on Justia Law

Branham began teaching in 1983 and was a tenured law professor. She sometimes suffered from seizures. She had a 12-month teaching contract for 2006. For the spring semester she was assigned to teach constitutional law and torts. Branham indicated that she did not want to teach the classes, citing health reasons and her greater experience with criminal law. She nonetheless taught the courses. In summer Branham sold her house, moved to Illinois, and was granted a leave of absence. Assigned to teach constitutional law after returning from leave, she refused to do so. The dean terminated her employment in December. Her contract required that dismissal be voted upon by faculty. That process was not initially followed. Branham sought damages for violations of the Americans with Disabilities Act and the Michigan Persons with Disabilities Civil Rights Act, intentional infliction of emotional distress, and breach of contract. The district court dismissed all but the contract claim, granted a motion to limit the remedy on the contract-breach claim to equitable relief, held that the school had breached the contract, and ordered compliance. Faculty and the board of directors concurred in the dismissal. The district court entered judgment against Branham. The Sixth Circuit affirmed. View "Branham v. Thomas M. Cooley Law Sch." on Justia Law

Milliken & Company sued Brian Morin after he resigned from the company and started a new venture using Milliken's proprietary information. The primary basis of the suit was that Morin breached the confidentiality and invention assignment agreements he signed when he started working for Milliken. A jury found for Milliken, and the court of appeals affirmed. The Supreme Court granted certiorari to review the narrow issue of whether these agreements are overbroad as a matter of law. Upon review, the Court held that they were not and affirmed as modified. View "Milliken & Company v. Morin" on Justia Law