Justia Contracts Opinion Summaries

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

A subcontractor on a public project filed suit against the general contractor and an insurance company that provided a payment bond seeking to recover money owed under the subcontract after the general contractor defaulted. The subcontractor asserted a payment-bond claim against the insurance company and breach of contract, unjust enrichment, and other claims against the general contractor. The insurance company filed a motion for summary judgment on the payment-bond claim because the subcontractor mailed its pre-suit notice of claim to the general contractor listed on the subcontract rather than the address listed on the payment bond. The district court denied the motion and granted judgment against the insurance company. The court of appeals reversed. The Supreme Court affirmed, holding (1) pursuant to Minn. Stat. 574.31(2)(a), a claimant must serve notice on the contractor at its address as stated in the bond as a prerequisite to filing suit; and (2) the subcontractor in this case did not comply with the statutory notice requirements. View "Safety Signs, LLC v. Niles-Wiese Constr. Co., Inc." on Justia Law

Johnson Controls, Inc. contracted with a school district (the District) to provide design services. Johnson then subcontracted with Architectural Resources, Inc. Marshall Helmberger subsequently submitted a request to Johnson under the Data Practices Act for a copy of the subcontract. Johnson denied the request and withheld the contract. Thereafter, Helmberger filed a complaint with the Office of Administrative Hearings (OAH). An administrative law judge (ALJ) dismissed the complaint after a hearing, concluding that Helmberger did not establish that Johnson was performing a governmental function for the District within the meaning of Minn. Stat. 13.05(11)(a). The court of appeals reversed. The Supreme Court reversed, holding that Johnson was not obligated to disclose the subcontract under the Act because the subcontract was not public data under section 13.05(11)(a). View "Helmberger v. Johnson Controls, Inc." on Justia Law

Appellants hired Respondent as the general contractor to build a seasonal residence on Appellant's property. Respondent purchased a general liability insurance policy from Midwest Family Mutual Insurance Company that included an absolute pollution exclusion. Respondent later purchased a boiler for Appellant's home that bore a label warning that the boiler was designed to run on natural gas only. Respondent connected the boiler to a liquid propane line. Appellants were later transported to hospital due to carbon monoxide poisoning from the boiler. Appellants brought litigation against Respondent. Midwest initiated a declaratory judgment action, requesting that the district court find Midwest had no duty to defend or indemnify Respondent because coverage was barred under the absolute pollution exclusion. The district court denied Midwest's motion for summary judgment, concluding that it would be inappropriate to rule as a matter of law that the absolute pollution exclusion barred coverage under the facts in this case since Respondent did not cause any environmental pollution. The court of appeals reversed, holding that carbon monoxide constitutes a pollutant in the Midwest policy. The Supreme Court affirmed, holding that carbon monoxide released from a negligently installed boiler is clearly a "pollutant" that is subject to the absolute pollution exclusion of the Midwest policy. View "Midwest Family Mut. Ins. Co. v. Wolters" on Justia Law

Respondent credit union sought to foreclose on the homestead that Appellant and her husband (Husband) owned. The district court granted summary judgment to Appellant after concluding that the mortgage Appellant signed with Respondent was void under Minn. Stat. 507.02 because it was not also signed by Husband. The court of appeals reversed, concluding that the mortgage was valid because Husband had quitclaimed all of his interest in the homestead property to Appellant before the mortgage was executed. The Supreme Court reversed, holding that the mortgage signed by Appellant in favor of Respondent was void because (1) the mortgage at issue here did not meet any of the statutory exceptions to the signature requirement in section 507.02; and (2) Husband's quitclaim deed did not constitute an explicit waiver of his rights under the homestead statute. View "Marine Credit Union v. Detlefson-Delano" on Justia Law

Second Chance Investments, LLC (SCI) purchased a fire insurance policy from Auto-Owners Insurance Company (Auto-Owners) that covered a building with the limit of insurance set at $2,095,500. The building subsequently suffered extensive fire damage. SCI filed a proof of loss claiming the building was a total loss. Auto-Owners rejected the proof of loss, contending that it did not state the actual cash value of the loss as required by the policy or provide a written estimate of repair to support the claim. After a continued dispute over whether the property was a total loss, Auto-Owners ultimately filed a complaint in district court seeking an order compelling SCI to submit the issue of whether the building was a total loss to a binding determination by an appraisal panel. The district court denied Auto-Owners' motion to compel appraisal and dismissed its complaint. The court of appeals affirmed, concluding that a court, rather than an appraisal panel, is the appropriate forum to determine whether the property suffered a total loss. The Supreme Court affirmed, holding that a party to a fire insurance policy does not have the statutory right to have an appraisal panel decide whether a claim involves a total loss. View "Auto-Owners Ins. Co. v. Second Chance Invs., LLC" on Justia Law