Justia Contracts Opinion Summaries

Articles Posted in Montana Supreme Court
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In 2010, Havre High School’s roof partially collapsed. Dick Anderson Construction, Inc. (Anderson) built the roof and Springer Group Architects (Springer) designed it. Hill County High School District No. A filed suit against against Springer and Anderson, alleging negligence, breach of express and implied warranty, breach of contract, negligent misrepresentation, deceit, and fraud. The district court granted summary judgment in favor of Springer and Anderson, concluding that the statute of repose time-barred the School District’s claims. The Supreme Court affirmed, holding that the district court did not err in (1) concluding that the statute of repose barred the School District’s claims; (2) ruling that the period of repose could not be tolled; and (3) awarding Spring attorney fees under the contract. View "Hill County High School District No. A v. Dick Anderson Construction, Inc." on Justia Law

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Sheri Lee hired Morgan Pierce, PLLP to represent her in a bankruptcy proceeding. Morgan Pierce subsequently filed notice of an attorney’s lien against five pieces of Lee’s real property for legal services rendered. Joseph Mulroy and Lee then entered into an agreement for two of the pieces of property against which Morgan Pierce’s lien was recorded. Thereafter, Mulroy filed a petition for interpleader and declaratory relief asking the district court to determine the validity of Morgan Pierce’s attorney’s lien. The district court granted summary judgment in favor of Mulroy and awarded his costs and fees. The Supreme Court reversed, holding that the district court erred in holding that the agreement entered into between Morgan Pierce and Lee did not create a lien by consent. View "Mulroy v. Morgan Pierce, PLLP" on Justia Law

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JEM Contracting, Inc. (JEM) and Ohio Farmers Insurance Company (OFIC) executed two indemnity agreements so that JEM could obtain bonding from OFIC for construction projects. Thereafter, OFIC executed and delivered two surety bonds on behalf of JEM for two construction projects. JEM hired a subcontractor, Hollow Contracting (Hollow), to furnish labor and equipment for both projects. After a dispute arose between JEM and Hollow regarding payment for the work performed, Hollow filed a complaint against JEM and OFIC. The lawsuit was resolved, and the district court dismissed the litigation. Thereafter, OFIC filed a complaint seeking indemnification from JEM for attorney fees and costs incurred in the underlying litigation. In its answer, JEM alleged that the fees and costs OFIC incurred in the litigation were not covered under the indemnity agreements. The district court granted partial summary judgment on the pleadings in favor of OFIC, concluding that JEM was required to indemnify OFIC for “appropriate expenses.” The Supreme Court affirmed, holding that the district court did not err in granting partial summary judgment on the pleadings to OFIC on the limited issue of whether OFIC may seek indemnification from JEF pursuant to the indemnification agreements. View "Ohio Farmers Insurance Co. v. JEM Contracting, Inc." on Justia Law

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The parties in this case disagreed over the ownership and operation of an irrigation system on a ranch. Plaintiff filed a complaint against Defendants, arguing that Defendants had converted his property by exercising unauthorized dominion or control over the irrigation system, that Defendants had been unjustly enriched through their possession of the irrigation system, and that Defendants had caused him damages. Defendants filed counterclaims against Welu, alleging trespass and breach of contract. The district court entered judgment in favor of Defendants. The Supreme Court affirmed, holding that the district court did not err in (1) determining that the entire pivot irrigation system constituted a fixture; (2) concluding that Defendants did not breach the parties’ agreement concerning the pivot irrigation system; and (3) did not err in determining that Defendants were not unjustly enriched. View "Welu v. Twin Hearts Smiling Horses, Inc." on Justia Law

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At issue in this case was two oral contracts entered into between Ryffel Family Partnership, Ltd. (Ryffel Partnership) and Alpine Construction (Alpine). The first agreement was entered into in January 2007, and the second agreement was entered into in September 2007. Ryffel Partnership filed suit against Alpine. The jury found that Ryffel Partnership had breached both oral contracts but that Alpine should be awarded no damages for either breach. The jury further found that Ryffel Partnerhsip had been unjustly enriched by Alpine’s labor and awarded Alpine $50,348 in damages. The jury also found that Ryffel Partnership had breached the implied covenant of good faith and fair dealing and awarded $25,000 to Alpine. The district court amended the judgment to assign the jury’s damages award for unjust enrichment to its finding that Ryffel Partnership breached its contract. The court also struck the jury’s award for breach of the covenant of good faith and fair dealing. The Supreme Court affirmed, holding (1) the jury’s verdict was supported by substantial evidence; (2) the district court did not err in denying Ryffel Partnership’s motion for a new trial based on an inconsistent or illegal jury verdict; and (3) the district court did not err in denying Alpine’s motion for prejudgment interest. View "Ryffel Family Partnership Ltd. v. Alpine Country Construction, Inc." on Justia Law

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623 Partners, LLC obtained a judgment against R. Larry Hunter and Larry Hunter Development Co. (collectively Larry). In its effort to satisfy the judgment, 623 Partners alleged that properly originally owned by Hunter Development was fraudulently transferred to Larry Todd Hunter, Larry’s son. The district court concluded that the properly was fraudulently transferred in order to avoid subjecting the property to 623 Partners’ writ of attachment and that Todd was liable to 623 Partners for the proceeds he received from the sale of a parcel of the property. The Supreme Court affirmed. On remand, Todd argued that he was entitled to an offset from the judgment amount based on the value of the improvements that he made to the property and that the property was exempt from execution or forced sale because he had claimed it as his homestead. The district court rejected Todd’s assertions. The Supreme Court affirmed, holding that the district court did not err in determining that Todd was not entitled to an offset and correctly concluded that Todd did not qualify for a homestead exemption. View "623 Partners, LLC v. Hunter" on Justia Law

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S&P Brake Supply, Inc. and STEMCO LP entered into an alleged oral contract for a five-year arrangement to produce and sell remanufactured brakes. S&P later sued STEMCO for breach of contract, among other claims, arguing that STEMCO violated the terms of the parties’ alleged oral contract. STEMCO filed a motion for summary judgment and, when that motion was unsuccessful, a motion for judgment as a matter of law, claiming that the statute of frauds barred the oral contract and that the parol evidence rule precluded evidence of its formation. The district court denied the motions. A jury found for S&P and awarded it damages on the oral agreement. The Supreme Court affirmed, holding that the district court (1) did not err in denying STEMCO’s motion for summary judgment; (2) improperly submitted the question of part performance to the jury but properly submitted S&P’s promissory estoppel claim to the jury; (3) did not prejudicially err in excluding evidence proffered by STEMCO to rebut S&P’s breach of contract and damages claims; and (4) correctly denied costs to STEMCO. View "S & P Brake Supply, Inc. v. Stemco LP" on Justia Law

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This case related to circumstances surrounding a data entry error that resulted in a significant sum of money being deposited into the wrong bank account. Grizzly Security Armored Express (Grizzly Security) filed suit against Bancard Services (Bancard) and B&B Lounge and Leland Ruzicka (collectively, Ruzicka). The district court concluded that the claim against Ruzicka was time-barred under the pertinent statute of limitations and that the claims against Bancard failed for various reasons. The court further awarded attorney’s fees to Bancard. The Supreme Court affirmed, holding that the district court (1) did not err in granting summary judgment in favor of Ruzicka; (2) did not err in granting summary judgment in favor of Bancard; and (3) did not err in awarding attorney’s fees to Bancard under the terms of a contract between the parties. View "Grizzly Security Armored Express, Inc. v. Bancard Services, Inc." on Justia Law

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After Lisa Warrington accepted an offer of employment with Great Falls Clinic (the Clinic), she signed a written employment contract. On Warrington’s last day at her former job, the Clinic informed her it would not employ her after all. Warrington filed an action against the Clinic, asserting breach of contract, promissory estoppel, and breach of the covenant of good faith and fair dealing. The district court granted summary judgment on the breach of contract claim and found that the Wrongful Discharge From Employment Act (the Act) did not apply. The Clinic petitioned the Supreme Court for a writ of supervisory control, arguing that the district court made a mistake of law by concluding that the Act did not apply to the relationship between Warrington and the Clinic. The Supreme Court accepted the petition for supervisory control, affirmed the district court’s determination that the Act does not apply to the relationship between the parties, and affirmed the district court’s order granting summary judgment to Warrington on the breach of contract claim. View "Great Falls Clinic LLP v. Eighth Judicial Dist. Court" on Justia Law

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David and Alana Folsom filed a complaint against Eagle’s Rest, LLC and the City of Livingston claiming breach of contract, negligence, unjust enrichment, and quantum meruit. After a jury trial, the district court entered judgment specifying that plaintiffs recovered nothing from Eagle’s Rest but awarding damages as to Livingston. The court also awarded attorney fees to the Folsoms as the prevailing party. The Folsoms appealed, and Livingston cross-appealed. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court (1) did not err by excluding expert testimony of a professional appraiser; (2) did not err in excluding David Folsom’s expert testimony at trial; (3) properly instructed the jury regarding unjust enrichment; (4) erred by awarding negligence damages to the Folsoms; and (5) abused its discretion by awarding essentially all of the attorney fees incurred by the Folsoms. View "Folsom v. Livingston" on Justia Law