Justia Contracts Opinion Summaries

The Supreme Court reversed the district court’s judgments ruling that the Montana Public Employees’ Association (MPEA) breached its duty of fair representation (DFR) to Jeffrey Folsom and engaged in common law fraud, awarding Folsom attorney fees as an element of compensatory damages on his DFR claim and awarding $50,000 in punitive damages on his common law fraud claim. The Supreme Court held (1) Folsom’s separately pled common law fraud claim is necessarily subsumed in his DFR claim and is thus not independently cognizable in this case; (2) the district court did not err in denying Folsom’s claim for compensatory lost wages and benefits on his DFR claim; (3) the district court erred in awarding fees to Folsom as an element of compensatory damages on his DFR claim; (4) the district court erred in awarding punitive damages without a compensatory damages predicate; and (5) the district court abused its discretion in refusing to grant MPEA’s motions for postjudgment relief from its summary judgment. View "Folsom v. Montana Public Employees’ Ass’n" on Justia Law

In this breach of contract action, the district court properly granted summary judgment to Plaintiff because Defendant failed to present sufficient admissible evidence to establish a genuine issue of material fact.Plaintiff, the owner of a gravel pit, entered into a contract with Defendant, a limited liability company, in which Plaintiff agreed to provide Defendant crushed aggregate material for a project. Once Defendant had removed all of the materials from the pit that it needed, Defendant refused to pay Plaintiff’s final invoices, arguing that the contract did not specify how the parties would measure the amount of material taken from the gravel pit and that the materials should be measured by volume at the project. The district court granted summary judgment for Plaintiff, concluding that the contract unambiguously required Defendant to base payment on the tonnage of crushed aggregate weighed by Plaintiff’s scales. The Supreme Court affirmed, holding that the contract designated that the material was to be sold by weight - in this case by tons - and the gravel pit scales were the only place to weigh the material by the ton. View "Moore v. Goran, LLC" on Justia Law

Nan Stevenson purchased a fifth wheel trailer at the Billings, Montana location of Big Sky RV, Inc., a Montana corporation with its principal office registered in Bozeman, Gallatin County, Montana. Stevenson provided a down payment and financed the remainder of the purchase price through Ally Bank. Ally later initiated this complaint against Stevenson in Chouteau County, claiming that Stevenson had defaulted on her payment obligations under the loan agreement. Steven filed a third-party complaint against Big Sky, alleging damages for breach of contract, violation of the implied covenant of good faith and fair dealing, negligence, and violations of the Montana Consumer Protection Act (MCPA). Big Sky filed a motion for judgment on the pleadings and for change of venue, arguing that, under Mont. Code Ann. 30-14-133(1), venue was improper in Chouteau County and that the district court lacked subject matter jurisdiction over the MCPA claim. The district court denied the motion. The Supreme Court affirmed, holding that the district court did not err in determining that it had subject matter jurisdiction and that venue was proper in Chouteau County. View "Ally Financial, Inc. v. Stevenson" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part an order of the district court entering judgment in favor of Plaintiffs on their complaint against Defendants for breach of contract, negligent or intentional infliction of emotional distress, fraud, and unjust enrichment. The Supreme Court held (1) the district court erred in concluding that Plaintiffs had an enforceable contract to purchase real property; (2) the district court did not err in entering judgment against three of the defendants for actual damages; but (3) the case must be remanded for an entry of judgment against the remaining defendants because they were joined in this proceeding and Mont. Code Ann. 72-3-1012 required them to also bear the cost of the claim. View "Wood v. Anderson" on Justia Law

In 2002, Lone Moose Meadows, LLC (LMM) and Boyne USA, Inc. (Boyne) entered into an agreement wherein LMM would construct a ski lift and pay Boyne to operate it. The agreement stated that LMM shall be required to make depreciation payments for operating expenses. In 2008, Boyne filed suit for breach of contract based on LMM’s failure to make depreciation payments. In response, LMM argued that it was not obligated to make depreciation payments until Boyne owned the lift. The district court granted summary judgment in favor of Boyne. LMM appealed but also paid $634,328 to Boyne, satisfying the judgment. While the appeal was pending, LMM filed an action alleging that Boyne had engaged in wrongful collection efforts with respect to the first judgment. Boyne counterclaimed for breach of contract, asserting that LMM now owed depreciation expenses for the 2009-10, 2010-11, and 2011-12 ski seasons. LMM later voluntarily dismissed the wrongful collection claim. The district court granted summary judgment for Boyne on the counterclaim. The Supreme Court affirmed, holding that the district court properly allowed Boyne to pursue successive claims for breach of contract, and LMM’s argument that Boyne’s claims were barred by claim preclusion was unavailing. View "Lone Moose Meadows, LLC v. Boyne USA, Inc." on Justia Law

Landowners appealed from an order of the district court granting summary judgment to the City of Lewistown and allowing the City to annex portion of the Landowners’ properties. The Supreme Court affirmed, holding that the district court did not err in (1) concluding that the City followed the statutory annexation requirements of Title 7, chapter 2, part 43, Mont. Code Ann.; (2) concluding that the City had correctly determined that there were less than a majority of valid protests; (3) concluding that the Landowners were not denied equal protection of the law by the City’s decision of what properties to annex; and (4) concluding that the Landowners lacked standing to enforce a contract between the City and a subdivision developer. View "St. John v. Lewistown" on Justia Law

In this home construction contract dispute, the Supreme Court (1) affirmed the district court’s decision awarding contractual damages to Contractor and dismissing Homeowners’ counterclaims for damages and attorney’s fees; but (2) reversed the district court’s denial of Contractor’s right to foreclose its construction lien placed on Homeowners’ property and the court’s decision to deny Contractor attorney’s fees pursuant to the lien foreclosure statute. The Court held that the district court erred as a matter of law when it reasoned that Contractor was not entitled to a favorable judgment for the foreclosure of the construction lien on the basis of Homeowners’ dissatisfaction with the work performed. Remanded. View "Vintage Construction, Inc. v. Feighner" on Justia Law

In 2009, Atkins-Swanson applied and qualified for participation in the Self-Directed Personal Assistance Service Program, a government-sponsored program that allowed Atkins-Swanson to direct health-related tasks. Consumer Direct was Atkins-Swanson’s provider agency and provided administrative services to Atkins-Swanson during the course of her participation in the program. In 2013, Atkins-Swanson succumbed to a fatal overdose of buspirone. Lee Swanson, on his own behalf and on behalf of Atkins-Swanson’s estate, filed this action against Consumer Direct, alleging wrongful death, survivorship, and breach of contract. The district court granted summary judgment for Consumer Direct, concluding that Consumer Direct was statutorily immune from liability because it was not directing the personal-care services. The Supreme Court affirmed, holding that the district court correctly granted Consumer Direct’s motion for summary judgment and did not err by denying Swanson’s motion to alter or amend the judgment on the ground that the claims were foreclosed under Mont. Code Ann. 53-6-145. View "Swanson v. Consumer Direct" on Justia Law

After the loan secured by Susan Alexander’s property went into default, Bank of America, N.A. (BANA) initiated foreclosure proceedings. The property was sold to BANA after a trustee’s sale. When Alexander refused BANA’s demand to vacate the property BANA filed a complaint for unlawful detainer against Alexander. Alexander asserted counterclaims for breach of contract, breach of an oral agreement, and frivolous litigation. The district court granted summary judgment in favor of BANA, concluding that the foreclosure sale was valid and that Alexander was unlawfully holding possession of the property. The court also concluded that Alexander’s counterclaims were either barred by the statute of limitations or statute of frauds and that there was a lack of supporting evidence for her claims. The Supreme Court affirmed, holding (1) BANA was entitled to summary judgment and a writ of assistance based on unlawful detainer; (2) Alexander failed to state a claim of fraud; (3) Alexander’s claims of breach of written or oral contract and breach of oral agreement were barred by the statute of limitations and statute of frauds; and (4) Alexander did not properly allege or offer supporting evidence for her claim of unjust enrichment. View "Bank of America, N.A. v. Alexander" on Justia Law

After Robert Fitte burned tree branches on his property, a fire rose from the ashes of the burn and erupted into a wildfire known as the Corral Fire. At the time of the fire, Fitte carried two insurance policies issued by Mountain West Farm Bureau Mutual Insurance Company, including the commercial automobile policy at issue in this appeal. Fitte stipulated to entry of a judgment in favor of Associated Dermatology and Skin Cancer Clinic of Helena, P.C. Profit Sharing Plan and Trust for the benefit of Stephen D. Behlmer, M.D. (Behlmer). Fitte and Behlmer subsequently entered into an agreement wherein Fitte assigned his rights in the Mountain West policies to Behlmer. Behlmer then filed this action seeking a declaration that the automobile policy provided coverage for the Corral Fire damages. The district court ruled in favor of Behlmer and directed that the insurance proceeds be deposited into the district court. The Supreme Court reversed, holding that the district court erred in holding that there was coverage for the Corral Fire damage under Mountain West’s commercial automobile policy. View "Associated Dermatology & Skin Cancer Clinic of Helena, P.C. Profit Sharing Plan & Trust for the Benefit of Stephen D. Behlmer v. Mountain West Farm Bureau Mutual Insurance Co." on Justia Law