Justia Contracts Opinion Summaries

Defendants-Appellants Sandra Walker and Joseph Eilers were found liable for damages after breaching employment agreements, and for conspiring to interfere with Plaintiff-Appellee SolarBee, Inc.'s existing business relationships. Finding the trial court's findings of fact were sufficient and that the damages awarded were supported by the evidence, the Supreme Court affirmed damages awards against both Defendants. View "SolarBee, Inc. v. Walker" on Justia Law

Northern Oil & Gas, Inc. appealed a judgment ordering reformation of an oil and gas lease and quieting title to the oil and gas leasehold estate in Murex Petroleum Corporation, John H. Holt, LBK Sales & Service, Inc., Racer Oil & Gas, LC, and Double L, LLC. In 2007, a landman working for Morris Creighton signed an oil and gas lease with the original mineral holder. The lease was recorded, but a month later, a typographical error was discovered in the lease’s property description. Six months later, Creighton assigned his interest in the lease, with an exception of an overriding royalty interest, to Antares Exploration Fund, L.P. Antares then assigned its interest in the Creighton lease to Northern. Northern brought an action to quiet title against Creighton and Murex to determine rights of the parties to the oil and gas leasehold estate. Murex filed a third-party complaint against the original mineral rights holders, a cross-claim against Creighton, and a counterclaim against Northern. Upon review, the Supreme Court concluded that the district court erred in concluding, as a matter of law, that Creighton was not a good faith purchaser and the Court held that there was a question of fact whether Creighton had constructive notice when he acquired rights under the lease. The Court reversed the judgment and remanded the case for further proceedings. View "Northern Oil & Gas, Inc. v. Creighton" on Justia Law

Plaintiffs-Appellants Arthur and Joy Lynn Hayden, in their individual capacities and as co-conservators and co-guardians of Todd Hayden, and the law firm of Smith Bakke Porsborg Schweigert & Armstrong ("law firm") appealed the grant of summary judgment dismissing their claims against Medcenter One, Inc., and other medical providers for expenses and attorney fees incurred in securing payments from Todd Hayden's medical insurance company for his medical expenses. Upon review of the matter, the Supreme Court affirmed, concluding the district court did not err in ruling as a matter of law that the medical providers are not liable to the Haydens and the law firm under their asserted theories of unjust enrichment, quantum meruit, equitable estoppel and the common fund doctrine. View "Hayden v. Medcenter One, Inc." on Justia Law

K & L Homes, Inc. ("K & L") appealed the trial court's summary judgment declaring no coverage existed under K & L's commercial general liability ("CGL") policy with American Family Mutual Insurance Company ("American Family") for damages awarded against K & L in an underlying action. Upon review of the applicable case law pertinent to this matter, the Supreme Court concluded there could be an "occurrence" under the CGL policy at issue in this case. Therefore, the Court reversed the summary judgment and remanded the case for further proceedings. View "K & L Homes, Inc. v. American Family Mutual Ins. Co." on Justia Law

Plaintiffs-Appellants Terence and Rachel Barrett appealed the dismissal of their claims against Defendant-Appellee Harry Gilbertson (dba Harry Gilbertson Construction) in a contract dispute. Plaintiffs argued that the trial court erred in dismissing their breach of contract claims related to the construction of their house, and that the court abused its discretion in denying their motion for attorney's fees. Upon review of the trial court record, the Supreme Court concluded that Plaintiffs failed to establish Defendant breached the terms of the construction contract or that the trial court did abused its discretion in denying the Plaintiffs' claim for attorney's fees. View "Barrett v. Gilbertson" on Justia Law

Plaintiffs-Appellants Dennis and Evangeline Bakken appealed a judgment declaring the Bakkens no longer had an option to repurchase Pierce County property Paul and Evangeline Bakken sold to John and Bernadine Duchscher in 1991, and which the Duchschers later transferred to John Duchscher, Jr., and Ann Duchscher. Upon review of the trial court record and applicable statutory and case law authority, the Supreme Court reversed and remanded, concluding the district court erred as a matter of law in ruling that the Bakkens' option to repurchase the property had expired. View "Bakken v. Duchscher" on Justia Law

SM Energy Company appealed a summary judgment declaring that A.G. Golden and other plaintiffs were entitled to a four percent overriding royalty interest in leases and lands covered by a 1970 letter agreement and ordering SM to pay amounts due to Golden and the other plaintiffs for these interests, and an order denying SM's motion to amend or for relief from the judgment. Upon review of the matter, the Supreme Court concluded the district court erred in ruling as a matter of law that SM through its predecessors in interest, expressly assumed an "area of mutual interest" clause in the 1970 letter agreement and in expanding the judgment to include unpled and unlitigated properties within the area of mutual interest. Furthermore, the Court concluded the court correctly ruled as a matter of law that SM owed Golden and the other plaintiffs retroactive royalty payments on production from a certain well located on the subject property. View "Golden v. SM Energy Company" on Justia Law

Steam Brothers, Inc. appealed the grant of summary judgment in a declaratory judgment action by John Riedlinger, Dale Stroh, Kevin Vetter, Leo Horner, and Duane Leier, five individuals, collectively referred to as "licensees". The district court decided that the clear and unambiguous language of the license agreements did not obligate the licensees to provide Steam Brothers and its owner Jerry Thomas, with certain business information and precluded Steam Brothers from terminating the license agreements absent mutual consent of the parties. Upon review, the Supreme Court reversed and remanded, concluding the license agreements were ambiguous about the parties' rights and obligations. View "Riedlinger v. Steam Brothers, Inc." on Justia Law

In 1989, Southeastern recovered a judgment against David Herzig in a North Carolina court. In August 1998, the North Carolina judgment was transcribed and filed in North Dakota under the Uniform Enforcement of Foreign Judgments Act, and renewed in North Carolina in 2000, and was again transcribed and filed in North Dakota for enforcement purposes. In 2004, Alphild Herzig, David Herzig's mother, was joined as a party. In 2005, Southeastern moved for an order compelling Alphild Herzig to comply with Southeastern's discovery requests and requested sanctions. In June 2006, Southeastern moved to compel discovery and requested sanctions. The court granted Southeastern's motion for sanctions against Alphild Herzig contingent on submission of a checklist of items to be produced so the court could set a daily sanction for each item not provided. The court also found Alphild Herzig was in contempt and awarded attorney fees. In August 2006, Alphild Herzig moved for release from the sanctions. The court denied her motion. In 2008, Alphild Herzig moved for an order to dismiss her as a party in the original action and vacating the 2004 order joining her as a party and all subsequent orders issued against her, including the 2006 contempt orders. Southeastern opposed Alphild Herzig's motion to dismiss. However, Alphild Herzig died before the court ruled on the motion. The issue before the Supreme Court in this case was whether the daily sanctions imposed on Alphild Herzig under 2006 contempt orders abated at her death. Upon review, the Supreme Court found that the district court had not followed its instructions on whether a portion of the daily sanctions were intended to be money damages to compensate Southeastern or whether the sanctions were a forfeiture. As such, the Court reversed and remanded the district court to make that determination. View "Investors Title Ins. Co. v. Herzig" on Justia Law

Wendell Lund appealed a district court order dismissing his action against his mother Betty Lund for lack of personal jurisdiction. Wendell is the son of Orville and Betty Lund. Orville and Betty Lund owned real property in Bottineau County. Wendell claimed that in 1985 he entered into an implied contract with his parents whereby he agreed to provide certain labor and supplies to maintain the real property and to pay half of the real estate taxes, and that in exchange his parents agreed to convey the property to him. In 1991, Orville and Betty signed a deed purporting to convey their interest in the property to Orville and Wendell. When Orville and Betty divorced in 2010, the trial court found the 1991 deed was not a legitimate transaction, but rather had been an attempt to deprive Betty of her interest in the property and her homestead rights. The court included the entire value of the real property in the marital estate and awarded it to Orville. Betty received other offsetting property, and each party ultimately received approximately one-half of the marital estate. Betty Lund moved to Arizona in 2010. Since then, she held an Arizona driver's license, registered her vehicle in Arizona and where she registered to vote. In 2011, Wendell brought this action against his parents alleging they failed to comply with the 1985 implied contract. He sought damages and transfer of the real property to him. Wendell claimed that Betty could not be located for service of process, so service was made by publication. Betty entered a special appearance through her attorney and moved to dismiss the action against her, arguing she was a permanent resident of Arizona and the district court lacked personal jurisdiction over her. The district court concluded it lacked personal jurisdiction over Betty and subsequently dismissed Wendell's claims against both of his parents, to which Wendell appealed. Upon review, the Supreme Court concluded Betty Lund resided in North Dakota, owned real property, and allegedly entered into a contract regarding her property in North Dakota. Those contacts were sufficient under Rule 4(b)(2) to assert personal jurisdiction over her for the transactions related to those activities, and she was not immune from suit because she left. The Court concluded the district court erred in concluding it lacked personal jurisdiction over Betty Lund. View "Lund v. Lund" on Justia Law