Justia Contracts Opinion Summaries

In the State of Montana v. Sky M. Little Coyote, the Supreme Court of Montana dealt with an appeal by Little Coyote, who had been incarcerated and was appealing the revocation of his suspended sentence. Little Coyote argued that his time served had been incorrectly calculated and that, when correctly accounted for, his sentence had already expired before the State filed its revocation petition. The State argued that Little Coyote was bound by an agreement he had entered into regarding the time served.The Supreme Court reversed the lower court's decision and remanded the case for dismissal of the State's Petition for Revocation. The court found that Little Coyote's time served had indeed been inaccurately calculated. It ruled that the parties involved had been operating under a mutual mistake regarding the time Little Coyote had served. The court held that, when correctly calculated and credited, Little Coyote's sentence had expired nearly three months before the State filed its revocation petition. Thus, the disposition imposed on Little Coyote was deemed illegal as the lower court had lacked the authority to revoke or impose a disposition after the expiration of his sentence. View "State v. Little Coyote" on Justia Law

In the case before the Supreme Court of the State of Montana, the plaintiff, Kevin Barber, appealed against his former employer, Bradford Aquatic Group, LLC, alleging wrongful termination. Bradford Aquatic Group, a North Carolina-based company, had employed Barber as a Regional Business Development Manager for its Rocky Mountain region, which includes Montana. The employment contract between Barber and the company included a choice-of-law and forum selection clause, specifying that any disputes arising from the agreement would be governed by North Carolina law and adjudicated in North Carolina courts.Barber, a resident of Montana, argued that Montana law should apply to his claims of wrongful discharge, breach of contract, and bad faith, and that the suit should be heard in Montana. The district court dismissed Barber's claims due to improper venue, based on the choice-of-law and forum selection clauses in the employment agreement.Upon review, the Supreme Court of the State of Montana affirmed the district court's decision. The court found that the choice-of-law provision in the employment agreement was valid and that North Carolina law should apply to Barber's claims. The court also upheld the validity of the forum selection clause, concluding that it is enforceable under North Carolina law. Therefore, the court determined that the dispute should be adjudicated in North Carolina, not Montana. View "Barber v. Bradford Aquatic" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgments of the district court enforcing the parties' mediated memorandum of understanding (MOU) regarding a subdivision dispute and then implementing it in the form of a more formal final settlement agreement proposed by Developers for approval by the Town of Fort Peck, Montana, holding that the district court erroneously granted Developers judgment as a matter of law.The district court ultimately concluded that the mediated MOU was an independently valid and enforceable contract in accordance with its written terms and as approved by the Town Council at its closed meeting, thus granting Developers' motion to enforce and implement the mediated MOU. The Supreme Court reversed in part, holding that the district court erred in granting Developers judgment as a matter of law that the Town Council took action to approve the parties' mediated MOU at its closed meeting and that a genuine issue of material fact remained as to whether a majority a quorum of the Town Council satisfied the agreed condition precedent to contract formation and enforceability of the MOU. View "Hanson v. Town of Fort Peck" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgments of the district court adjudicating a parental interest and accompanying parenting plan regarding Father's minor child in favor of his non-parent ex-wife (Surrogate), holding that the district court erroneously made a child custody parenting plan determination involving a non-parent without the predicate parental interest implied as a condition precedent to imposition of a best interests-based parenting plan.Specifically, the Supreme Court held that the district court (1) correctly concluded that the preclusive terms of a gestational carrier agreement did not preclude Surrogate from later acquiring or establishing a parental interest and right to the extent independently authorized under Montana law; (2) did not err in finding and concluding that Father voluntarily signed the premarital agreement and that it ws thus a validly formed and enforceable contract; (3) did not erroneously reject Father’s assertion that the parent-child relationship provision was unenforceable as equitably unconscionable; and (4) erroneously adjudicated a non parent "parental interest" in favor of Surrogate without the required predicated finding of fact specified by Mont. Code Ann. 40-4-228(2)(a). View "Sayler v. Yan Sun" on Justia Law

The Supreme Court affirmed the judgment of the district court enforcing a settlement agreement between Duane Bender and Rebecca Estates, LLC (collectively, Bender) and Stacey Rosman providing for Bender's purchase of Rosman's property near Shepherd, holding that the district court did not err.Bender filed suit against Rosman alleging trespass and tortious interference with contract and seeking to quiet title. Prior to trial, the parties reached a settlement agreement providing for the purchase of Rosman's property by Bender. The district court issued an order enforcing the settlement agreement for the price of $202,000. Bender appealed. The Supreme Court affirmed, holding that the district court did not err by concluding that Rosman was entitled to specific performance of the settlement agreement. View "Bender v. Rosman" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment for United Fire and Casualty Company and concluding that Clifford Christian and/or his Estate were not owed a defense or indemnification for claims made against Christian in litigation brought by Linda and Albert Parisian, holding that there was no error.Christian contracted with a general contractor on his project to construct four townhomes, one of which was pre-sold to the Parisians. A subcontractor later sued the general contractor and Parisians to obtain payment for his work to landscape the homesites. Christian was named as a third-party defendant and sought defense and indemnification from United Fire, which had insured the general contractor with a liability policy for the period at issue. After United Fire denied Christian's request Christian's Estate initiated this action. The district court granted summary judgment to United Fire. The Supreme Court affirmed, holding that the complaint did not allege facts that if proven, would trigger policy coverage. View "Christian v. United Fire & Casualty Co." on Justia Law

The Supreme Court affirmed the order of the district court granting petitions made by Lorri Williams to formally probate the estate of Gerry Williams, her ex-husband, and to remove Vicki Hofedlt as personal representative of Gerry's estate, holding that the district court did not err or abuse its discretion.Gerry and Lorri had two daughters, Brittany Williams and Vicki, during their marriage and later divorced. After Gerry died, Lorri paid for his funeral expenses. Vicki then filed an application for informal probate. Lorri filed a creditor's claim claiming funeral expenses and then filed a petition for formal probate asserting that the divorce decree was a testamentary instrument that needed to be probated along with Gerry's will. Lorri also filed a petition to remove Vicki as personal representative of Gerry's estate. The district court granted both petitions. The Supreme Court affirmed, holding that Vicki was not entitled to relief on her claims of error. View "In re Estate of Williams" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing the complaint brought by Lustre Oil Company LLC and Erehwon Oil & Gas, LLC (collectively, Lustre Oil) for lack of subject matter jurisdiction, holding that the district court did not properly weigh the relevant jurisdictional factors.Lustre Oil filed an action against A&S Mineral Development Company, LLC seeking to quiet title and to invalidate A&S's interests in forty-one of the fifty-seven oil and gases leases operated by A&S within the Fort Beck Indian Reservation, home to the Assiniboine and Sioux Tribes. The district court dismissed the action for lack of jurisdiction, concluding that A&S was an arm of the Tribes entitling it to immunity. The Supreme Court reversed, holding (1) the district court did not err in concluding that A&S's incorporation under Delaware law did not favor immunity and in thus refusing to deny A&S tribal sovereign immunity based on state incorporation alone; and (2) consideration of the White factors weighed against the extension of sovereign immunity to A&S as an arm of the Tribes for the purpose of Lustre Oil's claims in this case. View "Lustre Oil Co. v. Anadarko Minerals, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court in favor of a group of eastern Montana farmers (Farmers) and against four affiliates of USA Biofuels, LLC (Affiliates) on Farmers' claims on a variety of contract and tort theories, holding that there was no error.In 2018, Farmers entered individual written contracts with USA Biofuels to grow 10,000 acres of hemp. Farmers brought this action alleging that they never received full payment from Defendants, including USA Biofuels and various affiliates. The district court concluded on summary judgment that USA Biofuels breached its contract and awarded damages. Farmers subsequently abandoned their contract claims and secured a tort judgment against Affiliates. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion when it entered judgment on the punitive damages award; (2) did not err in instructing the jury; and (3) did not err in ruling on summary judgment that three shareholders were alter egos of USA Biofuels. View "Romo v. USA Biofuels, LLC" on Justia Law

The Supreme Court affirmed the judgment, decree of foreclosure, and order of sale by the district court, and the orders and actions contained within these documents, holding that there was no error or abuse of discretion.Thermal Design, Inc. filed a complaint to foreclose its construction lien against Mark and Pam Duffy and Central Copters, Inc. The complaint also asserted claims against TNT Building Systems. A jury found that TNT, acting as an agent of Central Copters, entered into a contract with Thermal Design for the insulation system, and both TNT and Central Copters were jointly and severally liable for breaching the contract with Thermal Design. As to a crossclaim between TNT and Central Copters, the jury found that both parties breached their agreement but that only TNT incurred damages. The district court entered a final order restating that, as a matter of law, Thermal Design had a valid construction lien attaching to both the Duffys’ real property and Central Copters’ building that should be foreclosed. The Supreme Court affirmed, holding that the district court did not err or abuse its discretion in the proceedings below. View "Thermal Design, Inc. v. Thorson" on Justia Law