Justia Contracts Opinion Summaries

The case involves a dispute between an individual and two defendants whom he sued for breach of contract, fraud, intentional infliction of emotional distress, and defamation. After a bench trial, the trial court entered judgment in favor of the defendants on all claims. The plaintiff then filed multiple post-trial and post-judgment motions, alleging, among other things, that new evidence showed interference in the case by the Federal Bureau of Investigation. All of these motions were denied. Subsequently, the plaintiff filed several motions seeking to disqualify the presiding judge for alleged bias and misconduct, each of which was also denied.Following these filings, the trial court judge issued an order declaring the plaintiff a vexatious litigant and enjoining him from filing further pleadings without first obtaining the court’s permission. The plaintiff appealed, raising issues about the vexatious litigant order, the denial of his motions to disqualify the judge, and the completeness of the record on appeal.The Supreme Court of the State of Montana reviewed the case. It held that the trial court abused its discretion by declaring the plaintiff a vexatious litigant and issuing a pre-filing order without first providing notice and an opportunity to be heard. The court vacated the vexatious litigant order and remanded for further proceedings, requiring the trial court to allow the plaintiff a chance to be heard and then, if warranted, issue a substantive order with adequate analysis. The Supreme Court affirmed the denial of the plaintiff’s motions for judicial disqualification, finding the motions procedurally deficient, and concluded that the trial court transmitted a sufficient record on appeal. The judgment was affirmed in part, reversed in part, and remanded for further proceedings. View "Heaven v. Weber" on Justia Law

A former Army specialist was seriously injured in a suicide bombing at a U.S. military base in Afghanistan. The attack was carried out by Ahmad Nayeb, a Taliban operative hired by Fluor Corporation, a military contractor, as part of a program encouraging the hiring of Afghan nationals. The Army’s investigation concluded that Fluor was primarily responsible due to negligent supervision and failure to enforce proper security procedures, including allowing Nayeb to check out tools used in the bombing and to move about the base unsupervised. The plaintiff sued Fluor in federal court in South Carolina, seeking damages under state law for negligent supervision, negligent entrustment, and negligent retention of Nayeb.The United States District Court for the District of South Carolina granted summary judgment to Fluor, holding that state-law tort claims were preempted under Fourth Circuit precedent whenever they arose out of combatant activities in a wartime setting. The United States Court of Appeals for the Fourth Circuit affirmed, adopting a broad “battlefield preemption” doctrine. It reasoned that the Federal Tort Claims Act’s (FTCA) combatant-activities exception, which preserves government immunity for claims arising out of military combatant activities, reflected an intent to bar all tort suits against contractors connected with those activities, regardless of whether the contractor followed or violated military instructions.The Supreme Court of the United States vacated the Fourth Circuit’s judgment and remanded the case. The Court held that the Fourth Circuit erred in finding the state-law tort claims preempted where the federal government neither ordered nor authorized the challenged conduct. The Supreme Court clarified that neither the Constitution, federal statutes, nor its precedents support such broad preemption. Preemption applies only if the contractor was following government directives or if there is a significant conflict between federal interests and state law, which was not the case here. View "Hencely v. Fluor Corp." on Justia Law

A San Diego family suffered a significant mistake after the sudden death of their relative, Jose Gonzalez, Jr., in Texas. Due to a mix-up at the Tarrant County Medical Examiner’s Office, the body of Mr. Gonzalez was confused with another individual who died a day later. As a result, the family received the wrong body for burial, while Mr. Gonzalez’s remains were mistakenly cremated in Texas. The widow, Celina Gonzalez, contracted with a California mortuary to arrange for Mr. Gonzalez’s body to be transported and prepared for funeral services in California. However, due to the error, the family discovered the mistake only at the viewing and could not bury their loved one as intended.Following these events, two lawsuits were filed in the Superior Court of San Diego County: one by the extended family and one by Celina and her daughter Edna. The cases were consolidated. The operative complaint alleged breach of contract and negligence. At trial, the mortuary asserted the affirmative defense of impracticability of performance, which the trial judge submitted to the jury. The jury found for the mortuary on both negligence and breach of contract, concluding that performance was excused due to impracticability. The trial court also granted nonsuit to the mortuary, ruling that only Celina, as the contracting party, had standing to sue for breach of contract, and that the extended family were not intended third-party beneficiaries.The California Court of Appeal, Fourth Appellate District, Division One, held that the defense of impracticability of performance is equitable and must be decided by the judge, not a jury. The appellate court reversed the judgment on the breach of contract claim as to Celina, remanding for a bench trial on the impracticability defense and, if necessary, a trial on damages. The court affirmed the dismissal of the extended family’s contract claims, finding they lacked standing. View "Gonzalez v. Community Mortuary" on Justia Law

A woman was injured after slipping and falling in the parking lot of an automobile repair shop. She filed a claim with the shop’s insurance provider, which began covering some medical and wage expenses. After the insurance company’s representative informed her that liability for her claim was being accepted, the claimant ceased gathering evidence or seeking legal counsel, believing liability would not be contested. Over two years later, when settlement negotiations failed, she retained an attorney and sued both the repair shop and the insurer. After settling with the shop and dismissing it from the lawsuit, the claimant pursued multiple claims against the insurer, including breach of contract, promissory estoppel, spoliation, and equitable estoppel, contending that the insurer’s communications led her to detrimentally alter her conduct regarding evidence collection.The Fourth Judicial District Court initially indicated from the bench that the insurer was estopped from denying liability, but ultimately denied the claimant’s motion for partial summary judgment and granted summary judgment to the insurer on all claims. The District Court concluded that under Montana law as it existed before a 2023 statutory amendment, a third-party claimant could only bring statutory or common law bad faith claims against an insurer for mishandling a claim, and that the claimant had not sufficiently pled or could not prove the elements of her other asserted causes of action.The Supreme Court of the State of Montana held that, under the pre-2023 version of Montana law, third-party claimants are not restricted to statutory or common law bad faith claims and may assert other causes of action such as breach of contract or torts based on how an insurer handled a claim. The Court affirmed summary judgment for the insurer on promissory estoppel, breach of contract, and insufficiently pled claims, but reversed summary judgment on spoliation and equitable estoppel, remanding those claims for further proceedings. View "D'Hooge v. Cincinnati Insurance Co." on Justia Law

Mitchell Glenn Revette sought medical care from Dr. Andrew Mallette at The Surgical Clinic Associates, P.A. for abdominal pain and underwent surgery for diverticulitis in June 2021. He later returned for a follow-up surgery in January 2022, after which he died due to complications related to respiratory depression. His wife, Nitkia Revette, brought a wrongful death and medical negligence lawsuit on behalf of his estate, alleging that negligent anesthesia and pain management led to his death.The defendants, Dr. Mallette and the Clinic, moved to compel arbitration based on an arbitration agreement included in an intake packet mailed to Mitchell. The agreement was signed "Mitchell Revette," but during a hearing in the Hinds County Circuit Court, Nitkia testified that she signed her husband’s name without his knowledge or presence, and she stated she had no authority to sign for him. The Clinic’s staff testified that patients were required to sign such agreements personally. The circuit court found that Mitchell did not sign the arbitration agreement and that Nitkia lacked authority to bind him, thus ruling the agreement unenforceable and denying the motion to compel arbitration.On appeal, the Supreme Court of Mississippi reviewed the circuit court’s findings, applying a deferential standard to factual determinations and de novo review to the denial of arbitration. The Supreme Court affirmed the circuit court’s decision, holding that substantial evidence supported the findings that Nitkia lacked both actual and apparent authority to sign for Mitchell and that there was no basis for binding the estate via direct-benefits estoppel. The case was remanded to the circuit court for further proceedings. View "Mallette v. Revette" on Justia Law

Linda Elam, after suffering significant medical issues including a stroke and complications from cancer treatment, was admitted to a nursing home operated by BLC Lexington SNF, LLC for rehabilitation. Her sister, Bonnie Townsend, acting under a power of attorney, handled the admission process and signed both the admission and an optional arbitration agreement as Elam’s representative. Following further health decline, Elam died, and her estate alleged that her death resulted from negligent care at the facility.After the estate filed suit in Kentucky state court against BLC Lexington and a former administrator, BLC Lexington responded in federal court, seeking to compel arbitration based on the agreement Townsend signed. The United States District Court for the Eastern District of Kentucky compelled arbitration for nearly all claims except wrongful death claims by nonsignatories. An arbitrator, after a week-long hearing, ruled in favor of BLC Lexington on all claims, finding Townsend had not met her burden of proof. The district court then confirmed the arbitration award, denying Townsend’s motions for reconsideration and to vacate the award.On appeal to the United States Court of Appeals for the Sixth Circuit, Townsend argued that compelling arbitration was improper because she did not sign as attorney-in-fact, that the arbitration agreement was indefinite, and that post-arbitration relief was warranted due to alleged arbitrator misconduct and the application of an incorrect legal standard. The Sixth Circuit affirmed the district court’s decisions, holding that the arbitration agreement was enforceable under Kentucky law, Townsend had acted as Elam’s representative, and no intervening change in law or arbitrator misconduct justified vacating the award. The court also found the arbitrator applied the correct evidentiary standard. The judgment of the district court was affirmed. View "BLC Lexington SNF, LLC v. Bonnie Town" on Justia Law

Two former seasonal employees of a ski resort were injured in a snowmobile accident after being laid off from their jobs. The accident occurred when, two days after their termination, they returned to the resort to drop off uniforms and accepted a ride from a current employee on a company snowmobile to attend a gathering organized by other former employees. The snowmobile crashed, causing serious injuries. Prior to their employment, both injured parties had signed a release agreement that waived the resort’s liability for injuries sustained from activities on resort property, including those caused by the resort’s negligence. The agreement specified that a free ski pass was consideration for the waiver.Both individuals brought lawsuits against the resort alleging vicarious liability for the employee’s negligence and direct liability for its own negligence. The Third District Court, Summit County, granted summary judgment in favor of the resort on the vicarious liability claims, finding no evidence the employee was acting within the scope of employment during the snowmobile ride. However, the district court denied summary judgment on the direct liability claims, relying on Pugmire v. Oregon Short Line Railroad Co., a 1907 Utah Supreme Court decision holding that employer-employee agreements waiving liability for employer negligence are void as contrary to public policy.On interlocutory appeal, the Supreme Court of the State of Utah affirmed the dismissal of the vicarious liability claims, concluding that there was no factual basis for a jury to find the employee acted within the course and scope of his employment. The court reversed the district court’s ruling on direct liability, holding that Pugmire applies only to releases for work-related injuries and does not bar enforcement of the waiver in this case, where the injuries occurred outside the employment context. The case was remanded for consideration of any other arguments regarding the release agreement. View "Deer Valley v. Olson" on Justia Law

A woman with dementia was admitted to a memory care facility, where her family warned staff about her tendency to wander and need for supervision. Three days after admission, she was found unattended in a courtyard on a 102-degree day, suffering from severe burns and heatstroke, ultimately dying days later. Her family, acting as successors in interest and individually, sued the facility for elder neglect, negligence, fraud, wrongful death, and negligent infliction of emotional distress. Upon admission, her niece had signed an arbitration agreement on her behalf, which the family argued should not bind their individual claims or override their right to a jury trial.The Superior Court of Sacramento County considered the facility’s motion to compel arbitration and stay the proceedings. The court found a valid arbitration agreement existed for the decedent’s survivor claims but ruled that the agreement did not bind the family members' individual claims, as they were not parties to the agreement. The court also declined to compel arbitration of the survivor claims under California Code of Civil Procedure section 1281.2, subdivision (c), citing the risk of conflicting rulings if the family’s claims proceeded in court while survivor claims were arbitrated. The court further held that the agreement’s reference to the Federal Arbitration Act (FAA) did not expressly incorporate the FAA’s procedural provisions to preempt California law.On appeal, the California Court of Appeal, Third Appellate District, affirmed the trial court’s judgment. It held that the arbitration agreement did not clearly and unmistakably delegate threshold issues of arbitrability to the arbitrator, and that the FAA’s procedural provisions were not expressly adopted by the agreement. Therefore, California law applied, and the trial court properly exercised its discretion to deny arbitration to avoid inconsistent rulings. The judgment was affirmed, and costs were awarded to the plaintiffs. View "Wright v. WellQuest Elk Grove" on Justia Law

A homeowner alleged that he hired a roofing company in 2011 to install a specific type of roof on his residence. After installation, problems with roof materials became apparent, including issues with a protective layer that remained unresolved despite multiple repair attempts by both the roofing company and the manufacturer over more than a decade. The homeowner asserted that these defects persisted, and that communication from the roofing company ceased in early 2024. As a result, he filed a lawsuit in Etowah County, Alabama, alleging breach of express and implied warranties, as well as negligent or wanton installation and repair, and sought damages.The roofing company moved to dismiss the lawsuit for improper venue, arguing that a forum-selection clause in a “Service Agreement” required all disputes to be heard in Madison County, Alabama. The company attached an unsigned and undated sample agreement to its motion, but did not produce a copy signed by the homeowner or any evidence that the homeowner had agreed to such a clause. The homeowner responded that he had never signed, nor was he aware of, the agreement submitted by the company and also challenged the clause’s reasonableness. The Etowah Circuit Court denied the company’s motion to dismiss for improper venue.The Supreme Court of Alabama reviewed the company’s petition for a writ of mandamus, which sought to compel the lower court to dismiss the case or transfer it to Madison County. The Supreme Court held that the company failed to meet its burden of proving that the forum-selection clause applied, as it did not present evidence linking the blank agreement to the parties’ actual contract. Therefore, the Supreme Court of Alabama denied the petition, concluding that the circuit court did not clearly err in refusing to dismiss or transfer the case. View "Ex parte Continental Roofing Company, LLC" on Justia Law

A tenant and her adult son rented a house in Arlington, Virginia, for a year. Several months into the lease, they noticed water leaking through a skylight and informed the landlord. The landlord and a contractor inspected the skylight and confirmed it was leaking, but no repairs were made. After a period of snow and rain, the tenant slipped on water that had accumulated from the leak, suffering significant injuries. She then sued the landlord, alleging breach of contract for failing to complete repairs as required by the lease and state law, and common-law negligence in failing to take steps to prevent injury from the leak.The landlord removed the case to the United States District Court for the Eastern District of Virginia, which treated the landlord’s demurrer as a motion to dismiss. The district court dismissed the negligence claim, finding the complaint did not allege that the landlord or contractor undertook repairs or performed any negligent acts—only that they inspected and confirmed the leak. The court concluded Virginia law does not impose a tort duty on landlords for failing to repair, but only for negligent acts in the course of repair. The breach of contract claim survived the motion to dismiss, but the parties later stipulated to voluntarily dismiss it to allow an immediate appeal.The United States Court of Appeals for the Fourth Circuit first determined it had appellate jurisdiction, accepting the tenant's binding representation that she was abandoning the contract claim with prejudice. The court then affirmed the district court’s dismissal of the negligence claim. It held that, under Virginia law, a landlord is not liable in tort for failing to make repairs unless the landlord undertakes repairs and does so negligently. Because the complaint did not allege any negligent repair or positive act, only nonfeasance, the negligence claim failed as a matter of law. View "Metz v. McCarthy" on Justia Law