Justia Contracts Opinion Summaries

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

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

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

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

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

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

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

Sean Melton purchased four parcels of property from Len Wallace. Lee Foss represented Wallace. The parties contractually agreed that Melton would pay Foss $112,000 in commission. Foss later filed suit against Melton for the unpaid balance of the commission. Melton moved for summary judgment, arguing that Foss had not exhausted his available remedies pursuant to the “exhaustion of remedies” clause in the contract. Foss also moved for summary judgment. The district court granted summary judgment in favor of Foss and awarded attorney’s fees. The Supreme Court affirmed in part and reversed and remanded in part, holding that the district court (1) erred in granting summary judgment in favor of Foss because, while Foss did not fail to exhaust available remedies, it was inappropriate for the court to decide certain factual questions on summary judgment; and (2) erred in awarding attorney’s fees to Foss. View "Foss v. Melton" on Justia Law

Junkermeir, Clark, Campanella, Stevens, P.C. (Junkermeir) was a Montana accounting firm with offices in several Montana cities. Junkermeir lost its Bozeman branch office after the majority of its Bozeman shareholders decided to start their own firm, taking a significant number of Junkermier’s clients with them. Junkermeir filed a complaint against the former shareholders, claiming breach of contract and breach of fiduciary duty. The district court dismissed the breach of contract claim on summary judgment, concluding that the contractual covenant restricting competition that Junkermeir sought to enforce was unenforceable. After a trial, the district court ruled that most of the former shareholders owed no legal duty to Junkermeir and that while the remaining former shareholder breached his fiduciary duty to Junkermeir, Junkermeir failed to prove awardable damages from that breach. The Supreme Court reversed in part and affirmed in part, holding that the district court (1) erred in ruling that the agreement was not an enforceable contract; and (2) did not err in concluding that only one former shareholder breached a fiduciary duty but erred in concluding that Junkermeir was not entitled to collect any damages stemming from that breach. View "Junkermier, Clark, Campanella, Stevens, P.C. v. Alborn, Uithoven, Riekenberg, P.C." on Justia Law

Chris Wagner sued MSE Technology Applications, Inc. and related MSE entities (collectively, the MSE entities) and Butte Local Development Corporation (BLDC), alleging that they had improperly interfered with his attempt to purchase certain property to establish a commercial nursery. Plaintiff later amended his complaint to add Shea Relators as a defendant. The district court dismissed Wagner’s claims at trial pursuant to Mont. R. Civ. P. 50. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in granting judgment as a matter of law to the MSE entities and BLDC; but (2) erred in granting Shea Realtors summary judgment and judgment as a matter of law. Remanded. View "Wagner v. MSE Technology Applications, Inc." on Justia Law