Justia Contracts Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of the district court awarding $2,353,463 in damages to Junkermier, Clark, Campanella, Stevens, P.C. (JCCS), a Montana accounting firm, after a bench trial on remand, holding that the district court did not err by awarding prejudgment interest but erred with regards to the date interest began accruing.Appellants, five of six shareholders in JCCS' Bozeman office, were employed under the terms of an Employment Agreement that contained a covenant restricting competition (Covenant). Appellants later began working at a newly formed accounting firm and solicited clients from JCCS' Bozeman client list. JCCS filed a complaint against Appellants to declare the Covenant enforceable and to recover damages. On remand, the district court determined that the Covenant was reasonable, Appellants were jointly and severally liable for damages arising out of the Covenant's breach, and JCCS was entitled to prejudgment interest. The Supreme Court largely affirmed, holding that the district court did not err by (1) concluding that Appellants were jointly and severally liable for JCCS' damages; (2) concluding that the Covenant was reasonable; (3) awarding prejudgment interest but erred with regards to the date interest began accruing; and (4) by denying Appellants' motion for discovery sanctions. View "Junkermier, Clark, Campanella, Stevens, P.C. v. Alborn" on Justia Law

The Supreme Court reversed the judgment of the district court adjudicating that Defendant satisfied the judgment debt on Plaintiff's successful breach of contract claim, holding that the district court erred in adjudging Plaintiff's judgment fully satisfied without inclusion of additional post-judgment interest that continued to accrue during a stay of execution obtained by Defendant pending appeal.A jury returned a verdict awarding Plaintiff contract damages. Plaintiff appealed adversing rulings on her other claims, and Defendant cross-appealed various adverse trial rulings. Defendant then moved for a stay of execution of judgment, which the district court granted. The Supreme Court affirmed the judgment. On remand, Defendant moved for declaration that it fully satisfied Plaintiff's adverse judgment. The district court granted the motion. The Supreme Court reversed the judgment of satisfaction, holding that the district court erroneously adjudged Plaintiff's judgment fully satisfied without regard for additional post-judgment interest that accrued during the stay of execution pending appeal. View "Warrington v. Great Falls Clinic, LLP" on Justia Law

The Supreme Court affirmed the order of the district court certifying three classes of more than 30,000 ratepayers of the City of Billings who challenged certain franchise fees that the City imposed on water, wastewater, and solid waste disposal services, holding that the district court did not abuse its discretion when it certified the classes.After the City ceased imposing the franchise fees in 2018 the Ratepayers sued the City alleging that the fees constituted unlawful sales taxes. Ratepayers brought claims for breach of contract and constitutional due process violations. The Ratepayers sought class action certification for those similarly situated persons who paid the water and wastewater fees since 2010 and the sold waste disposal fees since 2012. The district court granted the motion and certified three classes. The Supreme Court affirmed, holding that the district court did not err when it certified the classes under Mont. R. Civ. P. 23(b)(3). View "Houser v. City of Billings" on Justia Law

The Supreme Court reversed the judgment of the district court denying PointCentral, LLC's motion to dismiss third-party claims of Big Sky Vacation Rentals, Inc. (BSVR) pursuant to Mont. R. Civ. P. 12(b), holding that the district court erred in concluding that the PointCentral/BSVR arbitration agreement was invalid or otherwise unenforceable due to lack of mutuality or equitable unconscionability.BSVR and PointCentral entered into an agreement that included a broadly-worded arbitration agreement. After BSVR was sued for contract and tort claims BSVR asserted third-party claims against PointCentral for contribution and indemnification. Based on the arbitration agreement, PointCentral filed a motion for dismissal of BSVR's third-party claims. The district court denied the motion, concluding that the agreement lacked mutual consideration and was thus unenforceable as a matter of generally applicable contract law. The Supreme Court reversed, holding that the district court erred in failing to dismiss BSVR's third-party claims because the arbitration was not unenforceable due to lack of mutuality or equitable unconscionability and did not contravene the letter or underlying purpose or policy of Mont. Code Ann. 27-1-703(4)-(5). View "Big Sky Vacation Rentals, Inc. v. PointCentral, LLC" on Justia Law

In this contract dispute, the Supreme Court affirmed the judgment of the district court awarding Flathead Management Partners (FMP) $191,876 in expectancy damages, holding that the district court did not err when it denied Gary Jystad's motion for judgment on the pleadings and when it concluded that the contract at issue was enforceable.After a fire destroyed Jystad's home he entered into a contract with FMP to restore the property and to oversee the reconstruction of the main residence. After the parties worked together for a few months, Jystad informed FMP that the contract was void because it did not contain the statutorily required disclosures for a general contractor constructing a new residence. FMP filed this action claiming expectancy damages for the full contract price. The district court granted judgment for FMP, holding that FMP was not a general contractor and that the contract was not for the construction of a new residence. The Supreme Court affirmed, holding (1) the district court did not err when it determined that the contract was not for the construction of a new residence and that FMP was not a general contractor; and (2) the court did not abuse its discretion in the award of damages. View "Flathead Management Partners, LLC v. Jystad" on Justia Law

The Supreme Court affirmed the district court's grant of summary judgment in favor of Wells Fargo Bank, N.A. and dismissing Plaintiff's claims for, inter alia, breach of contract and negligence, holding that Wells Fargo did not breach the deed of trust and that Plaintiff's remaining claims presented no genuine issue of material fact.Wells Fargo assumed service of a loan obtained by Plaintiff, who executed a deed of trust with certain property serving as collateral for the loan. Plaintiff failed to pay property taxes assessed to Lot 3, which included the property. Wells Fargo paid the taxes on the entirety of Lot 3 and required Plaintiff to repay those taxes. Plaintiff later brought this suit. The district court granted summary judgment for Wells Fargo, reasoning that the deed of trust's unambiguous language permitted Wells Fargo to pay Lot 3's taxes in full. The Supreme Court affirmed, holding (1) under the deed of trust, Wells Fargo did not breach of the contract by paying the delinquent taxes on lot 3 and requiring Plaintiff to repay those taxes; and (2) because Wells Fargo did not breach the deed of trust, it likewise did not violate a duty owed to Plaintiff under the deed of trust, and as such Plaintiff's remaining claims were properly dismissed. View "Graham-Rogers v. Wells Fargo Bank, N.A." on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment in favor of Barbara Needham in her capacity as the personal representative of the Estate of Charles Kelly Kluver (Estate) and denying the cross-motion for summary judgment filed by Karson Kluver and Genie Land Company (collectively, Kluver), holding that the district court did not err in granting summary judgment.The Estate filed a complaint for declaratory judgment and for dissolution of Genie against Kluver, alleging declaratory judgment, breach of contract, promissory estoppel, and judicial dissolution of corporation. The Estate filed a petition for partial summary judgment. The district court granted partial summary judgment in favor of the Estate in Counts I and II and denied Kluver's cross-motion for summary judgment in its entirety. The Supreme Court affirmed, holding that the district court did not err in granting partial summary judgment in favor of the Estate. View "Needham v. Kluver" on Justia Law

The Supreme Court reversed the order of the district court granting the motion of the Sandra L. Farber Trust (Farber) to enforce the parties' punitive settlement agreement and denying Karen Jarussi's cross-motion for enforcement, holding that the district court erred by concluding that the parties formed a legally binding settlement agreement.This dispute arose from the parties' disagreement on how their punitive settlement agreement should be interpreted. The parties filed opposing motions for enforcement, and the district court determined that the parties must comply with the agreement as interpreted by Farber. The Supreme Court reversed and remanded this matter for further proceedings, holding that the parties did not mutually assent to the scope of their proposed agreement. View "Jarussi v. Farber" on Justia Law

The Supreme Court reversed the judgment of the district court denying the motion to compel arbitration filed by Edwards Jones & Company, Jeremy Kientz, and Nick Ferranto (collectively, Edwards Jones) of post-termination claims asserted against them by former Edward Jones employee Adam Bucy, holding that Bucy's claims were mandatorily arbitrable and within the scope of the arbitration agreements.Bucy, who worked for Edward Jones for approximately nineteen years primarily as a financial advisor, was terminated after an internal review. Bucy filed a complaint against Edward Jones asserting claims for statutory blacklisting, statutory defamation, and common law tortious interference with a prospective business relationship. Edward Jones moved to dismiss and compel arbitration of Bucy's claims on the basis that they were subject to arbitration under Financial Industry Regulatory Authority, Inc. (FINRA) and National Association of Securities Dealers, Inc. (NASD) regulations and two arbitration agreements between the parties. The district court denied arbitration of post-employment claims, concluding that the claims were not arbitrable within the scope of the arbitration agreements. The Supreme Court reversed, holding that the arbitration agreements were valid and enforceable, that Bucy's claims were mandatorily arbitrable, and that the claims were within the scope of the arbitration agreements. View "Bucy v. Edward Jones & Co." on Justia Law

The Supreme Court affirmed the judgment of the district court granting Plaintiff's motion for judgment on the pleadings, holding that the district court did not err in granting Plaintiff's motion for judgment on the pleadings because Defendants breached an agreement between the parties.Plaintiff sued Defendants for breaching an agreement between the parties to purchase a 2974 pressurized Cessna Skymaster 337 from Plaintiff for $90,000. When Defendants informed Plaintiff they would not be making the purchase due to their inability to obtain insurance, Plaintiff brought this action. The district court found Defendants liable for breaching the agreement and granted Plaintiff's motion for judgment on the pleadings. The Supreme Court affirmed, holding that the district court did not err in granting Plaintiff's motion for judgment on the pleadings, denying Plaintiff's motion in limine, sanctioning Plaintiff, and denying Plaintiff's motion for pre-judgment interest. View "Kalispell Aircraft Co. v. Patterson" on Justia Law