Justia Contracts Opinion Summaries

In this appeal arising from a set of commercial construction projects the Supreme Judicial Court affirmed the judgment in favor of Fortney & Weygant, Inc. (F&W) on the counterclaims filed by Lewiston DMEP IX, LLC, et al. (collectively, GBT) for liquidated damages, affirmed in part as to the prompt payment remedies allowed to F&W, and vacated the portion of the judgment awarding attorney fees and costs to F&W pursuant to the terms of the parties' contract.The trial court determined that, in addition to damages for breach of contract, F&W was entitled to remedies, including attorney fees pursuant to Maine's prompt payment statutes, that F&W was entitled to attorney fees pursuant to the terms of the parties' contract, and that GBT was estopped from seeking to enforce a contractual right to liquidated damages against F&W. The Supreme Judicial Court held that the trial court (1) did not erroneously conclude that GBT was equitably estopped from recovering liquidated damages against F&W; (2) properly awarded F&W prompt payment remedies except to the extent that the remedy failed to account for the value of GBT's liquidated damages claims that GBT withheld in good faith; and (3) erred when it concluded that the contract contemplated an award of attorney fees outside the context of arbitration. View "Fortney & Weygandt, Inc. v. Lewiston DMEP IX, LLC" on Justia Law

The Supreme Judicial Court vacated the judgment of the district court dismissing Appellant's compliant alleging revocation of acceptance and breach of warranty as time-barred, holding that the court relied upon facts contained in documents that exceeded the scope of the facts that may be considered by the court in the context of a motion to dismiss.Appellant brought this action alleging claims with respect to a bicycle frame that he purchased that was manufactured by Independent Fabrication, Inc. The district court dismissed the complaint as barred by the four-year statute of limitations set forth in Me. Rev. Stat. 11, 2-725. The Supreme Judicial Court vacated the order of dismissal on procedural grounds and remanded for further proceedings, holding that the court's consideration of matters outside the pleadings in granting Independent's motion to dismiss was in error. View "Greif v. Independent Fabrication, Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court granting summary judgment in favor of Defendants on Plaintiff's claims alleging age discrimination, retaliation, breach of contract, and various other torts, holding that there was no error or abuse of discretion in the superior court's handling of Plaintiff's requested accommodations.On appeal, Plaintiff argued that the trial court abused its discretion by not, sua sponte, granting him accommodations, appointing him a guardian ad litem, or ordering that his mental health be evaluated. The Supreme Judicial Court disagreed, holding (1) the court did not err by granting summary judgment in favor of Defendants on all of Plaintiff's claims; and (2) the court properly handled Plaintiff's request for accommodations. View "Gallagher v. Penobscot Community Healthcare" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court denying Appellants' motions for judgment as a matter of law and a new trial following a jury verdict in favor of Appellee on his claims for breach of contract, breach of fiduciary duty, and fraudulent misrepresentation, holding that the superior court did not err.Specifically, the Court held that the superior court did not err by (1) allowing Appellee to proceed on a claim of fraudulent misrepresentation based upon allegation that Appellants did not intend to perform their obligations under the contract at the time it was executed; (2) failing to give a requested jury instruction; and (3) allowing Appellee to proceed on a claim for breach of fiduciary duty when the parties' relationship was governed by a limited liability company operating agreement. View "Cianchette v. Cianchette" on Justia Law

In this appeal involving a dispute over payment for the construction of a traditional timber frame home, the Supreme Judicial Court affirmed the judgment of the superior court calculating the damages recoverable under the Unfair Trade Practice Act (UTPA) stemming from Contractor’s violation of the Home Construction Contracts Act (HCCA), holding that, the superior court did not err in its judgment.Contractor brought this action seeking to be paid for his unpaid labor. The superior court concluded (1) Contractor was entitled to the money he had already received from Homeowners under the theory of quantum meruit; (2) Homeowners did not meet their burden of proof as to their counterclaims; and (3) Contractor violated the HCCA by failing to furnish a written contract, which was prima facie evidence of a UTPA violation. The Supreme Judicial Court affirmed, holding (1) while the parties did not sign a contract in this case, the superior court’s application of quantum meruit was appropriate; (2) the superior court did not err in concluding that Homeowners failed to prove their counterclaims; (3) Homeowners were not entitled to additional damages under the UTPA; and (4) the attorneys fees award in this case was sufficient. View "Sweet v. Breivogel" on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court affirming the judgment of the district court in favor of Appellee, Appellant’s landlord, holding that Appellant’s violation of his lease in three ways that were independent from his possession of marijuana justified Appellee’s termination of the lease.Appellee issued Appellant a notice that it was terminating the parties’ lease, stating that Appellant’s use and possession of marijuana, as well as some of Appellant’s other activities, violated the terms of the parties’ lease. Appellee then filed an forcible entry and detainer complaint, and the district court entered judgment granting possession of the apartment to Appellant. Appellant appealed, arguing that because he had a certificate to use marijuana for medical purposes, Appellee and the district court were required to reasonably accommodate his possession and use of marijuana. The Supreme Judicial Court affirmed, holding that Appellant’s violations of his lease that were independent from his possession of marijuana, standing alone, justified Appellee’s termination of the lease. View "Sherwood Associates LP v. Jackson" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court granting summary judgment to Defendant, PropertyInfo Corporation, Inc., on York County’s complaint alleging breach of contract and unjust enrichment, holding that the court did not err in its determination that York County’s claims were barred by the statute of limitations.York County’s action was based on PropertyInfo’s failure to digitize and make accessible all documents filed with the York County Registry of Deeds between 1940 and 1965. The superior court entered a summary judgment in favor of PropertyInfo, concluding that the statute of limitations had expired on each of York County’s claims. The Supreme Judicial Court affirmed, holding that the superior court properly entered summary judgment based on the expiration of the statute of limitations on each of the claims. View "York County v. PropertyInfo Corp., Inc." on Justia Law

The Supreme Judicial Court affirmed the district court’s grant of partial summary judgment in favor of Avis Rent A Car System, LLC on Avis’s claim for breach of contract but vacated the court’s award of damages.Defendant, a Maine resident, rented a car from an Avis location in Las Vegas, Nevada. The vehicle was damaged when it was involved in an accident in Las Vegas. When Defendant refused to pay for the damages, Avis filed a complaint against Defendant, alleging breach of connect and negligence. The district court concluded that Avis was entitled to partial summary judgment on the breach of contract claim as a matter of law. After an evidentiary hearing, the court granted Avis its requested amount of $15,342 and also awarded attorney fees and costs. The Supreme Judicial Court reversed in part, holding that partial summary judgment as to liability was correctly granted but because Avis presented no admissible evidence as to the amount of damages, it failed to prove it was entitled to the damages awarded to it. The Court then remanded the case for an award of nominal damages in accordance with Nevada law. View "Avis Rent A Car System, LLC v. Burrill" on Justia Law

Maine attorneys must obtain a client’s informed consent regarding the scope and effect of any contractual provision that prospectively requires the client to submit malpractice claims against those attorneys to arbitration.The Supreme Judicial Court affirmed the judgment of the superior court denying Bernstein, Shur, Sawyer & Nelson, P.A.’s (Bernstein) motion to compel arbitration in a legal malpractice claim filed against it. The superior court concluded that Bernstein failed to obtain informed consent from Susan Snow, its client, to submit malpractice claims to arbitration and that federal law does not preempt a rule requiring attorneys to obtain such informed consent from their clients. The Supreme Judicial Court affirmed, holding that the superior court did not err in concluding that (1) Bernstein’s failure to obtain informed consent from Snow regarding an arbitration provision rendered that provision unenforceable as contrary to public policy; and (2) the Federal Arbitration Act does not preempt a requirement that attorneys obtain informed consent from their clients before contracting to submit disputes to arbitration. View "Snow v. Bernstein, Shur, Sawyer & Nelson, P.A." on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court granting Matthew Eastwick’s application to confirm an arbitration award and denying Cate Street Capital, Inc.’s competing motion to vacate that award after concluding that the parties had agreed to arbitrate any disputes arising from a settlement agreement. The Supreme Judicial Court held (1) the agreement contained clear contractual language of the parties’ intent to submit disputes to the mediator for binding arbitration; and (2) although the parties’ confidentiality had been compromised by the litigation, the court’s judgment incorporated the final agreement without ordering acceleration of those payments not yet due and without modifying any of its terms, including the agreement’s confidentiality provision. View "Eastwick v. Cate Street Capital, Inc." on Justia Law