Justia Contracts Opinion Summaries

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

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