Justia Contracts Opinion Summaries

Appellant Patrick Figgins brought suit against respondent Grand Rapids State Bank (GRSB) and its CEO, respondent Noah Wilcox, claiming, among other things, that Wilcox and GRSB had made misrepresentations and breached an oral agreement regarding the due date of a payment on an outstanding loan. Respondents moved to dismiss on the ground that Minn. Stat. 513.33 (2014) did not permit these claims. The district court agreed and dismissed the complaint with prejudice. Figgins, on appeal, argued that section 513.33 did not apply to his claims and, to the extent it did, his promissory estoppel claim should have survived because promissory estoppel was an exception to the statute. Finding no reversible error in the district court's judgment, the Minnesota Supreme Court affirmed. View "Figgins vs. Wilcox" on Justia Law

At issue in this case was whether truck drivers hauling asphalt cement from a commercial oil refinery to a contractor’s facility are performing “work under a contract” under Minn. Stat. 177.44(1) and, therefore, must be paid prevailing wages. The Minnesota Department of Transportation (MDOT) determined that the construction companies that were awarded contracts to work on state highway projects violated the project contracts by failing to ensure that drivers that assisted in the acquisition and transport of asphalt cement for the projects were paid prevailing wages. Appellants argued that the hauling activities of these drivers did not constitute “work under a contract” under Minn. Stat. 177.44(1) and, alternatively, that the hauling activities were exempt from the prevailing wage requirements under the “commercial establishment exception” in the Prevailing Wage Act. The district courts granted summary judgment to MDOT. The court of appeals affirmed. The Supreme Court reversed, holding that hauling activities must be to, from, or on the site of a public works project to qualify as “work under a contract,” and therefore, the hauling activities in this case did not constitute “work under the contract” subject to the prevailing wage requirements. View "J.D. Donovan, Inc. v. Minn. Dep’t of Transp." on Justia Law

Appellants’ homeowners insurance policy with State Farm Fire and Casualty Company provided that State Farm will be only the “actual cash value” at the time of the loss of damaged property. Appellants brought a putative class action lawsuit against State Farm, claiming that State Farm breached the terms of Appellants’ policy when it calculated the actual cash value of damaged property. Specifically, Appellants alleged that State Farm’s practice of depreciating embedded labor costs breached State Farm’s duty to indemnify the insured for the actual cash value of the damaged property. The district court certified a question regarding the issue to the Supreme Court. The Court answered that, absent specific language in the insurance policy that identifies the method of calculating actual cash value, the trier of fact may consider, among many other factors, embedded-labor-cost depreciation when such evidence logically tends to establish the actual cash value of a covered loss. View "Wilcox v. State Farm Fire & Cas. Co." on Justia Law

The apartment building in which Tenants lived was damaged by a fire. For purposes of this appeal, the parties agreed that the fire was caused by Tenants’ negligence. Landlord’s insurer paid for the repairs to the building and then brought this subrogation action against Tenants in the name of Landlord to recover the money it paid to repair the damage caused by the fire. The district court granted summary judgment in favor of Tenants, determining that the parties did not reasonably expect that Tenants would be liable for the damage they caused. The court of appeals reversed, concluding that the lease agreement clearly reflected the parties’ intention that Tenants would reimburse Landlord for any damage caused by their negligence. The Supreme Court affirmed in part and reversed in part, holding (1) under the circumstances of this case, it is reasonable that Tenants should be liable for negligence they caused to the leased premises; but (2) the parties would not reasonably have expected that Tenants would be liable for damage to other property belonging to Landlord. Remanded. View "Melrose Gates, LLC v. Moua" on Justia Law

Appellant represented a client pursuant to a contingent-fee agreement but voluntarily withdrew from the representation of the client when efforts to settle the case failed. The client subsequently retained substitute counsel, and substitute counsel successfully negotiated a settlement. Appellant filed suit seeking to recover in quantum meruit the value of the services provided prior to withdrawal. The district court entered judgment against Appellant, concluding that Appellant was not entitled to recover in quantum meruit because he failed to establish good cause for withdrawal. The Supreme Court affirmed, holding (1) an attorney may withdraw from a contingent-fee agreement with or without cause, provided that the withdrawal satisfies the rule of professional responsibility; (2) the attorney may recover in quantum meruit the reasonable value of the services rendered prior to withdrawal if the attorney establishes that the withdrawal is for good cause; and (3) Appellant in this case failed to establish good cause. View "In re Petition for Distribution of Attorney’s Fees between Stowman Law Firm, P.A., and Lori Peterson Law Firm" on Justia Law

Lyon filed a breach of contract action against Illinois Paper in federal district court, alleging that Illinois Paper had breached a contractual representation and warranty that all lease transactions presented to Lyon for review would be "valid and fully enforceable agreements." The Seventh Circuit certified questions to the court under Minn. Stat. 480.065. The court reformulated the questions and held that a claim for breach of a contractual representation of future legal compliance is actionable under Minnesota law without proof of reliance. View "Lyon Financial Services, Inc. v. Illinois Paper and Copier Co." on Justia Law

The Minnesota Laborers Health and Welfare Fund (“the Funds”) filed a declaratory judgment action against Granite Re, Inc. seeking clarification of their right to payment on a surety bond. The district court granted summary judgment to Granite Re, concluding, among other things, that the Funds’ lawsuit was time-barred because the Funds failed to commence litigation within the one-year contractual limitations period set out in the bond. The court of appeals reversed and remanded, concluding that fraudulent concealment by the bond principal tolled the limitations period set out in the bond. The Supreme Court affirmed, holding (1) fraudulent concealment can be applied to a surety that was not involved in the fraudulent concealment by the principal; and (2) therefore, the one-year contractual limitations period set out in the bond may be tolled against Granite Re. View "Minn. Laborers Health & Welfare Fund v. Granite Re, Inc." on Justia Law

Appellant entered into a mortgage with Aegis Lending Corporation. The mortgage was later assigned to Pacifica L. Ninteen, and the servicing rights were eventually transferred to Vantium Capital, Inc. (“Acqura”). After foreclosure proceedings were commenced against Appellant, Appellant filed suit against Acqura, alleging numerous state law claims. Specifically, Appellant claimed that Acqura’s violated its Servicer Participation Agreement with Fannie Mae by failing to follow guidelines applicable under the federal Home Affordable Modification Program. The district court dismissed the lawsuit, holding that Minn. Stat. 58.18(1) did not provide a private cause of action for Appellant to pursue damages for Acqura’s alleged violation of its agreement with Fannie Mae and that Appellant therefore lacked standing. The court of appeals affirmed. The Supreme Court reversed, holding that section 58.18(1) provides for a private right of action and therefore gave Appellant standing to pursue her claim. View "Gretsch v. Vantium Capital, Inc." on Justia Law

In 1986, the City of Duluth and the Fond du Lac Band of Lake Superior Chippewa (the Band) entered into several agreements establishing a joint venture to operate gaming activities in Duluth. The agreements required that the Band seek approval before creating any additional Indian Country. In 1994, the Band and the City created a series of new agreements and amendments to the 1986 agreements. In 2010, the Band acquired a plot of land. The Band sought to have the plot placed in trust but did not seek the City’s approval to do so, as required by the 1986 agreements. The City commenced this action in state district court seeking a court order requiring the Band to withdraw its trust application. The district court dismissed the lawsuit, concluding that it lacked subject matter jurisdiction because the Band had only consented to suit in federal court in the 1994 agreements. The court of appeals reversed. The Supreme Court reversed the court of appeals’ decision and reinstated the district court’s judgment for the Band, holding that the Court lacked jurisdiction to decide the issue of whether the Band breached the 1986 agreements because it required interpretation of the 1994 agreements, which was a matter vested in the federal courts. View "City of Duluth v. Fond du Lac Band of Lake Superior Chippewa" on Justia Law

Respondent brought this action against Appellant, seeking to recover payment for industrial equipment it fabricated for Appellant. Appellant counterclaimed for breach of contract. The district court entered judgment in favor of Respondent. Appellant filed a motion for judgment as a matter of law or a new trial, arguing that the district court erred in granting Respondent's motion for a protective order to preclude the depositions of two out-of-state witnesses from going forward shortly before trial. The district court denied the motion. The Supreme Court reversed, holding (1) the district court abused its discretion by granting Respondent's motion for a protective order because it applied the wrong legal standard in this case; (2) Respondent did not demonstrate good cause to preclude Appellant's depositions of the out-of-state witnesses; and (3) because Appellant was prejudiced by the district court's error, a new trial was warranted. View "TC/Am. Monorail, Inc. v. Custom Conveyor Corp." on Justia Law