Justia Contracts Opinion Summaries

The underlying dispute in this appeal revolved around the issue of who was contractually obligated to pay workers' compensation benefits to an employee of Employer. The Supreme Court found that Employer's Insurer was required to pay workers' compensation benefits for all of Employer's employees and remanded the case. The district court entered a final judgment. Instead of filing a notice of appeal within thirty days of the district court's judgment, Insurer filed an "objection to judgment." Insurer then filed its notice of appeal within thirty days of the district court's order disposing of that motion. The Supreme Court dismissed the appeal, holding that it lacked jurisdiction to address the appeal as (1) Insurer did not file its notice of appeal within thirty days of the district court's final judgment, and (2) Insurer failed to file a postjudgment motion that would toll the time for appeal or one that the Court had jurisdiction to review.

Plaintiffs commenced a diversity action against defendant, asserting claims for breach of the insurance contract and for vexatious refusal to pay. Applying Missouri law, the district court granted defendant summary judgment, concluding that the insurance policy at issue unambiguously excluded losses caused by plaintiffs' CEO, a shareholder, and by plaintiffs' COO, a non-shareholder, acting in collusion with the CEO. The court affirmed and held that the Officer-Shareholder exclusion was consistent with Missouri public policy, and in the alternative, the Officer-Shareholder exclusion was unambiguous and excluded plaintiffs' claim.

Eric Spannbauer, a police officer with the North Las Vegas Police Department, was asked to resign by the City Police Department Association. Spannbauer resigned, signing a letter of agreement prepared by the Department. Spannbauer later filed a complaint with the Employee-Management Relation Board (EMRB) against the Association, the City, and the Department, alleging multiple prohibited practices in violation of Nev. Rev. Stat. 288, including gender discrimination. The EMRB found that the City and Department had committed prohibited labor practices and that the Association had breached its duty of fair representation. The City and the Department petitioned the district court for judicial review, which the district court denied. The City, on behalf of itself and the Department, filed an appeal. The Supreme Court affirmed, holding that there was substantial evidence to support the EMRB's finding that the City and Department discriminated against Sannbauer on the basis of his gender in violation of Nev. Rev. Stat. 288.110(1)(f); and (2) the EMRB appropriately disregarded the resignation agreement, including the covenant not to sue, as there was substantial evidence that the agreement was a culmination of prohibited practices in violation of Nev. Rev. Stat. 288.270(1).

This case stemmed from plaintiff's allegations that, while she was employed with defendant on one of its cruise ships, she was drugged by other employees, raped, and physically injured while she was unconscious, and when she reported to officials of the cruise line what had happened to her, they treated her with indifference and even hostility, failed to provide her with proper medical treatment on board, and interfered with her attempts to obtain medical treatment and counseling ashore. Plaintiff subsequently asserted five claims against defendant involving violations of the Jones Act, 46 U.S.C. 30104, or the general maritime law applicable to the Seaman's Wage Act, 46 U.S.C. 10313. Plaintiff's remaining five claims involved common law tort claims. At issue was whether plaintiff's claims fell within the scope of the arbitration clause in the crew agreement. The court held that the district court did not err in holding that Counts VI, VII, VIII, IX, and X of plaintiff's complaint did not fall within the scope of the arbitration provision where all five of these claims involved factual allegations about how the cruise line and its officials treated plaintiff after learning that she had been raped, including allegations that she was kept on the ship against her will, that she was prevented from getting medical attention off the ship, that her rape kit was destroyed in the incinerator, and that her confidentiality as a rape victim was intentionally violated. The court held, however, that the remaining five counts arose directly from her undisputed status as a "seaman" employed by defendant and fell within the scope of the arbitration provision. Therefore, the district court erred in denying defendant's motion to compel arbitration for Counts I, II, III, IV, and V.

This case arose when plaintiff lost his right to previously awarded, but unexercised, Restricted Units under Merrill Lynch's "Long-Term Incentive Compensation Plan for Managers and Producers" (the Plan). Plaintiff asserted that he had a right to his Restricted Units under an exception to the general rule, that employees lost their rights to Restricted Units not heretofore unexercised, because he left the firm for "Good Reason" after a "Change in Control." The district court granted summary judgment to plaintiff, holding that, under the applicable standard of review, Merrill Lynch's interpretation of the Plan was arbitrary. The court held that plaintiff failed to meet his burden of showing that no honest tribunal could have construed the Plan in any manner but his proffered reading and that Merrill Lynch had advanced an arbitrary reading of the Plan. Accordingly, the court reversed and remanded.

The Union, representing certain employees at ExxonMobil's Baton Rouge refinery and chemical plant, brought suit to compel ExxonMobil to arbitrate two labor grievances pursuant to the parties' collective bargaining agreement. The court held that it was within the province of the courts to decide whether "a good faith claim by one party that the other party had violated a written provision" of the bargaining agreement had been asserted. The court also held that, in light of the clairty of the parties' agreement, the Union's claim that ExxonMobil violated Section 1131 of the agreement when the language of that section explicitly authorized its actions was not colorable and could not constitute a good faith claim within the meaning of the arbitration clause. The court agreed with ExxonMobil that Baton Rouge Oil & Chemical Workers Union v. ExxonMobil Corp foreclosed reliance on Section 1151 of the agreement as an independent basis for the arbitrability of the contracting-out grievance. The court further held that for the same reasons that the court held that the contracting-out grievance was not arbitrable under Section 1151, Section 1151 could not serve as a basis for requiring arbitration of the post-reduction claim. Accordingly, the court reversed the district court's grant of the Union's motion for summary judgment with regard to the contracting-out grievance, affirmed the district court's denial of the Union's motion for summary judgment with regard to the post-reduction grievance, and reversed the district court's denial of ExxonMobil's motion for summary judgment.

Plaintiff, employee, brought an action against Defendants, an archdiocese and a parish pastor, claiming that their refusal to renew her contract for employment as the principal of the parish school constituted, inter alia, wrongful termination in violation of public policy, breach of implied contract and breach of promissory estoppel. The trial court denied Defendants' motion to dismiss the action on the ground that adjudication of Plaintiff's claims called for impermissible judicial interference in the internal governance of the archdiocese with respect to its selection of religious leaders. At issue on appeal was whether the ministerial exception to judicial authority that precludes a court from adjudicating certain religious disputes required dismissal of the action. The Supreme Court first determined it had subject matter jurisdiction over the interlocutory appeal, and then reversed the trial court, holding that (1) in considering whether the ministerial exception is applicable in a particular case, a Connecticut state court must follow the Rweyemamu v. Cote standard; and (2) the ministerial exception applied to the various claims in the plaintiff's complaint. Remanded with direction to dismiss Plaintiff's complaint.

In 1996, when their company (LS&H) was bought out, defendants signed confidentiality and non-competition agreements for a term of "12 months after termination of my employment with LS&H;" each was paid $2,500 for signing the agreements, which were assignable and contemplated the sale. Each defendant accepted employment with the buyer, but refused to sign a new noncompetition agreement. They continued to work, even after the buyer merged with OfficeMax, until they were terminated in 2009 and 2010. Each found work doing essentially what they had done in the past. The district court entered a preliminary injunction, prohibiting defendants from selling office supplies. The First Circuit vacated. The contract is unambiguous; the triggering date for the noncompetition provision is termination of employment from LS&H. OfficeMax has not demonstrated a likelihood of success on the merits.

This case arose because the settlement of a personal-injury suit brought by a recipient of workers' compensation benefits against a third-party tortfeasor did not make any provision to repay the statutory subrogee, the Ohio Bureau of Workers' Compensation. The Bureau brought suit against both the recipient of the workers' compensation benefits and third-party tortfeasor under Ohio Rev. Code 4123.931(G) to recover the full amount of its subrogation interest. The trial court held that a two-year limitations period applied and that it had expired. The court of appeals reversed, holding that a six-year limitations period applied and that it had not yet run out. At issue on appeal was whether a claim under section 4123.931(G) brought by a statutory subrogee to recover its subrogation interest is subject to a two-year statute of limitations, the same period applicable to the injured worker's personal-injury suit against the third party, or to a six-year statute of limitations for an action on a liability created by statute. The Supreme Court affirmed the court of appeals, holding that the claim in this case was an action upon a liability created by statute and that the statute of limitations was six years.

In this appeal, accounting firm Bryan Brothers sought coverage under a professional liability insurance policy issued by Continental Casualty Company for liability arising from illegal acts of a former Bryan Brother's employee. Under the policy, it was a condition precedent to coverage that no insured had knowledge, prior to the inception of the policy, of an act that was reasonably likely to become the basis for a claim. The court held that because Bryan Brothers had such knowledge, the claims at issue were not covered. Therefore, the court affirmed the district court's grant of summary judgment to Continental Casualty Company.