Justia Contracts Opinion Summaries

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

Michael Mandell and Bayliss Ward and Bayliss Architects, P.C. (Bayliss) agreed that Bayliss would provide architectural and construction services for Mandell’s home. Mandell refused to pay Bayliss’s final invoice, and Bayliss filed a construction lien on the property. Mandell initiated this action stating counts of breach of contract, declaratory judgment that the lien was invalid, and quiet title to the property. Bayliss counterclaimed for foreclosure of the construction lien, quantum meruit, and breach of contract. The district court partially granted Mandell’s claim for declaratory relief, ruling that because Bayliss failed to obtain a written contract for construction services, the contract was void and the lien for those services was invalid. After a trial, the district court granted relief in quantum meruit and awarded attorney fees to Bayliss. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court (1) did not err in granting equitable relief in quantum meruit, despite violation of the statutory requirement that residential construction contracts be in writing; and (2) erred in awarding attorney fees for the quantum meruit claim. Remanded. View "Mandell v. Bayliss Ward" on Justia Law

When David Goldan began working as an independent contractor insurance agent for Farmers Insurance Exchange, Farmers and Goldan entered into an Agency Appointment Agreement defining the parties’ rights and obligations. After Farmers terminated Goldan, Farmers sued Goldan alleging that Goldan breached his contractual duties and fiduciary responsibilities under the Agreement by soliciting and servicing the insurance business of policyholders within a year of his termination. Goldan counterclaimed for breach of contract, alleging that Farmers terminated him without cause. The jury ruled in favor of Goldan on all issues. The Supreme Court affirmed, holding that the district court did not err (1) by denying Farmers’ motion for judgment as a matter of law on the question of damages; (2) in denying Farmers’ motion for sanctions based on Goldan’s alleged discovery violations; and (3) in concluding that damages should not be limited to a three-month notice period allowed in the contract for terminations without cause. View "Farmers Ins. Exchange v. Goldan" on Justia Law

Plaintiffs and Defendants owned real property on a peninsula in Echo Lake. Defendants owned a parcel on the southern end of the peninsula, through which the sole vehicular road granting access to the northern lots owned by Plaintiffs ran. Defendants purchased their property subject to a long-term existing easement allowing Plaintiffs access to their properties. In 1992, the parties entered into a road maintenance agreement setting forth the responsibilities of the parties regarding maintenance of the access road. When a flood damaged the road, Plaintiffs filed a complaint seeking declaratory judgment that the maintenance agreement was valid and enforceable and alleging that Defendants breached the agreement. Defendants counterclaimed. The district court entered judgment in favor of Defendants. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) erred by concluding that the maintenance agreement was unenforceable against Defendants for lack of consideration, but the error was harmless; (2) did not err by ruling that Defendants did not breach the maintenance agreement; and (3) did not err by ordering Plaintiffs to pay Defendants’ counterclaim-related attorney’s fees and costs. View "Low v. Reick" on Justia Law

Plaintiffs (the Friedmans) purchased a professional archery retail sporting goods business owned by Aaron and Constance Lasco. The Lascos entered a covenant not to compete with the Friedmans that was incorporated into the purchase and sale agreement. After the sale was final, Aaron Lasco went to work at Sportsman & Ski Haus (Sportsman). Sportsman subsequently expended its business to include a new archery department. Thereafter, the Friedmans filed several breach of contract claims against the Lascos, including breach of the covenant not to compete. The Friedmans also requested a preliminary injunction to stop Aaron Lasco from further employment at Sportsman until their claims were resolved. The district court found the covenant not to compete was valid and granted the Friedmans’ preliminary injunction request. The Supreme Court affirmed the district court’s decision to grant a preliminary injunction to the Friedmans, holding that the Friedmans demonstrated that they were likely to succeed on the merits of their claims against the Lascos. View "Friedman v. Lasco" on Justia Law

Pacific Steel & Recycling entered into a contract with Emineth Custom Homes to build four duplex apartment units. The contract specified that Pacific would advance a $474,625 down payment to Emineth upon execution of the contract. After canceling the contract for the duplexes Pacific brought an action against Emineth seeking recovery of the down payment made to Emineth under the contract. Emineth counterclaimed, alleging breach of contract and other claims. A jury determined that Emineth did not breach the contract with Pacific but that Pacific breached the contract with Emineth. The jury awarded $238,241 in Emineth’s favor. The district court entered judgment on the verdict in favor of Emineth but ordered that Emineth’s jury award in its favor become a judgment against Emineth and in favor of Pacific for $236,189. The Supreme Court affirmed in part and reversed in part, holding (1) the jury’s verdict with regard to the finding that Pacific breached the contract with Emineth stands; but (2) the district court in rendering the judgment made a factual determination contrary to the verdict returned by the jury. Remanded for entry of a judgment of $238,241 against Pacific and in favor of Emineth. View "Pacific Hide & Fur Depot v. Emineth Custom Homes, Inc." on Justia Law

For more than a century, Asarco LLC and its predecessors operated a lead smelting facility (the Site). For almost fifty years, Atlantic Richfield Company’s predecessor operated a zinc fuming plant on land leased from Asarco at the Site. Atlantic Richfield subsequently sold the plant and related property to Asarco. Due to extensive contamination at the Site, the Environmental Protection Agency determined that Asarco was obligated to fund cleanup efforts at the Site. After conducting extensive remediation at the Site, Asarco filed a complaint seeking contribution pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) from Atlantic Richfield, asserting that Atlantic Richfield was liable under CERCLA for its equitable share of costs related to the Site’s cleanup. The federal district court granted summary judgment for Atlantic Richfield, concluding that Asarco’s claims were untimely under CERCLA’s statute of limitations. Asarco then commenced the present action against Atlantic Richfield alleging several state-law claims. The district court granted Atlantic Richfield’s motion for judgment on the pleadings on the ground that the doctrine of claim preclusion barred Asarco’s claims. The Supreme Court affirmed, holding that claim preclusion barred Asarco’s action because Asarco could have brought its state-law claims before the federal district court in Asarco I. View "Asarco LLC v. Atlantic Richfield Co." on Justia Law

Julia Fenwick and the State, Department of Military Affairs and Emergency Services Division (Department) executed a Severance Agreement whereby the Department agreed to lay off Fenwick, as opposed to discharging her, in exchange for Fenwick releasing any claims she had against the Department. Fenwick later filed this action alleging that the Severance Agreement should be rescinded for several reasons. The district court concluded as a matter of law that the Severance Agreement could not be rescinded. The Supreme Court affirmed, holding that the district court did not err by (1) ruling that the Severance Agreement was lawful; and (2) ruling that the undisputed facts established that the Department’s consideration for the Severance Agreement did not fail. Remanded with instructions to proceed on Fenwick’s remaining claims. View "Fenwick v. State" on Justia Law