Justia Contracts Opinion Summaries

The First Circuit vacated in part the district court’s grant of summary judgment in Defendants’ favor on Plaintiffs’ claims seeking compensatory damages, declaratory relief, a permanent injunction, and expungement of disciplinary proceedings from a student’s university records.John Doe was accused of sexually assaulting a fellow Boston College student. In 2012, Boston College held disciplinary proceedings against Doe, and an Administrative Hearing Board found Doe responsible for the lesser offense of indecent assault and battery. In 2014, Boston College conducted an independent review of the disciplinary proceedings and determined that the Board’s finding was proper. Doe and his parents filed a lawsuit against Trustees of Boston College and several university officials. The district court granted summary judgment in favor of Defendants on all counts. The First Circuit (1) affirmed the district court’s grant of summary judgment as to Plaintiffs’ breach of contract claim for the 2014 review and Title IX, negligence, and negligent infliction of emotional distress claims; and (2) vacated the grant of summary judgment as to Plaintiffs’ breach of contract claim for the 2012 disciplinary proceedings, where there were genuine issues of material fact on this claim, and basic fairness claim, where the grant of summary judgment on this claim rested on the court’s analysis as to Plaintiffs’ breach of contract claim. View "Doe v. Trustees of Boston College" on Justia Law

At issue here was cross-claims arising out of a bail bondsman’s attempt to seize a bailed man who had failed to appear for a court hearing.Rodriguez, the bailed man, left New Jersey to return to his home in Puerto Rico in violation of the bail agreement. When Rodriguez missed a court date in New Jersey, the bail bond was declared forfeited. Agents acting for Speedy Bail Bonds seized Rodriguez in Puerto Rico. Rodriguez filed suit against Speedy seeking damages for his seizure and detention. Rodriguez’s mother as co-plaintiff claimed mental anguish. Speedy counterclaimed for breach of the bail agreement. The jury returned a verdict in favor of Speedy. The First Circuit affirmed the damages award on the counterclaim but remanded the case to the district court for further proceedings on the question of whether the jury instructions as to the tort claims accurately reflected Puerto Rico law because the question of Puerto Rico law and out-of-state bounty hunters had not been briefed. View "Rodriguez-Tirado v. Speedy Bail Bonds" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the district court dismissing Plaintiff’s amended complaint against several lenders, holding that the district court did not err in dismissing some of Plaintiff’s claims but erred in dismissing the remaining claims.After Plaintiff defaulted on her loan on real property, she received at least nine notices of sale. Plaintiff filed an amended complaint against Lenders, alleging six causes of action. The district court granted Lenders’ motion to dismiss the amended complaint pursuant to Mont. R. Civ. P. 12(b)(6). The Supreme Court held that the district court (1) did not err in dismissing Plaintiff’s declaratory judgment claim as a matter of law or in dismissing Plaintiff’s negligent and/or intentional infliction of emotional distress claim fore failure to state sufficient facts to entitle her to relief; and (2) incorrectly determined that Plaintiff’s amended complaint failed to state a claim on her asserted breach of contract and breach of the implied covenant of good faith and fair dealing, Fair Debt Collection Practices Act (FDCPA), and Montana Consumer Protection Act (MCPA) claims. View "Puryer v. HSBC Bank" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the superior court granting summary judgment for Defendant, Price Rite, on count one of Plaintiff’s complaint and also granting Defendant’s motion to dismiss the remaining four counts.Plaintiff slipped and fell on liquid in an aisle of a store owned by Defendant. Plaintiff’s amended complaint alleged negligence, breach of contract, mode of operation, failure to warn, and breach of the implied warranties of merchantability, fitness for use, and fitness for a particular purpose. The court granted summary judgment on the negligence count and dismissed the remaining counts. The Supreme Court vacated the judgment of the superior court granting summary judgment on Plaintiff’s negligence claim and affirmed the dismissal of the remaining counts, holding (1) Plaintiff satisfied her burden of producing competent evidence that proved the existence of a disputed issue of material fact with respect to Defendant’s safety procedures or lack thereof, (2) the trial judge impermissibly weighed the evidence in his decision granting summary judgment, and (3) there is no requirement at the summary judgment stage for a plaintiff to produce direct evidence of how long a spill has existed on a floor. View "Dent v. PRRC, Inc." on Justia Law

The business-owners liability insurance policy in this case did not provide coverage for a negligent supervision claim arising out of an alleged employee’s intentional act of physically punching a customer in the face.The circuit court granted summary judgment in favor of the Insurer, concluding that there was no coverage under the policy for either the employee’s intentional act or the negligent supervision claim against the employer arising out of the employee’s intentional act. The court of appeals reversed. The Supreme Court reversed, holding that where the negligent supervision claim pled rested solely on the employee’s intentional and unlawful act without any separate bais for a negligence claim against the employer, no coverage existed. View "Talley v. Mustafa" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the decision of the district court granting summary judgment to Anethesiology Consultants of Cheyenne, LLC (ACC) on its breach of fiduciary duty claim and on Dr. Ronald Stevens’ defamation counterclaim.ACC filed suit against Dr. Stevens and Cassandra Rivers alleging nine causes of action. Dr. Stevens counterclaimed against the members of ACC, alleging several causes of action, including defamation. The district court granted summary judgment for ACC on its first three causes of action and granted summary judgment for the counterclaims defendants on all of Dr. Stevens’ counterclaims. On appeal, the Supreme Court held (1) summary judgment was improperly granted on the fiduciary duties claims; (2) summary judgment was properly granted on the defamation counterclaim; and (3) the trial court erred in excluding certain email evidence. View "Stevens v. Anesthesiology Consultants of Cheyenne, LLC" on Justia Law

At issue was what findings a court must make in order to require attorney’s fees to be paid to an adverse party who was subjected to proceedings that were brought in bad faith or lacked substantial justification and what the appropriate means are for calculating attorney’s fees when a court determines that a party’s complaint includes claims that have substantial justification and claims that lack substantial justification.Respondents prevailed in having the trial judge dispose of Petitioner’s claims after the close of the evidence. The hearing judge found no substantial justification for each of Petitioner’s claims against Respondents and awarded $300,000 in attorney’s fees to Respondents. The court of special appeals vacated the circuit court’s judgment, concluding that there was substantial justification as to some of Petitioner’s claims. The Court of Appeals affirmed, holding that the hearing judge (1) did not commit clear error in finding no substantial justification for the claims brought by Petitioner; but (2) abused his discretion in assessing $300,000 in attorney’s fees against Petitioner without articulating how he calculated his fees. View "Christian v. Maternal-Fetal Medicine Associates of Maryland, LLC" on Justia Law

At issue was whether an indemnity clause in a rental agreement required the renter to indemnify the rental company for the rental company’s negligence.The Tower Tap & Restaurant entered into an agreement to rent folding picnic tables from London Road Rental Center, Inc. for an event. Plaintiff injured his hip at Tower Tap’s event after one of the rented tables collapsed on him. Plaintiff sued Tower Tap and London Road. London Road filed a cross-claim against Tower Tap, seeking contractual indemnity based on the indemnity clause in the rental agreement. The district court granted summary judgment to London Road, concluding that the clause unequivocally covered liability for London Road’s own negligence. The court of appeals affirmed. The Supreme Court reversed, holding that the indemnity clause did not include express language that clearly and unequivocally showed the parties’ intent to transfer such liability to Tower Tap. View "Dewitt v. London Road Rental Center, Inc." on Justia Law

Plaintiffs failed to state claims for tortious interference with contract, misappropriation of trade secrets, unfair and deceptive practices, civil conspiracy, and unjust enrichment sufficient to survive Defendants’ motion to dismiss pursuant to N.C. R. Civ. P. 12(b)(6).After Plaintiffs asserted various causes of action against Defendants, including the "Metropolitan defendants" and "dancer defendants," the Metropolitan defendants and dancer defendants filed motions to dismiss the amended complaint in its entirety pursuant to Rule 12(b)(6). The business court granted the motion to dismiss as to all of Plaintiffs’ claims except for the claims for breach of contract, fraudulent misrepresentation, unjust enrichment, and punitive damages against the dancer defendants. The Supreme Court affirmed as modified, holding (1) Plaintiffs failed to state valid claims for forties interference with contract, unfair and deceptive practices, and unjust enrichment against the Metropolitan defendants; (2) Plaintiffs failed to state valid claims for misappropriation of trade secrets and civil conspiracy against all defendants. View "Krawiec v. Manly" on Justia Law

In this breach of contract and negligence action, the Court of Appeals held that the City of New York was an intended third-party beneficiary of an architectural services contract between Dormitory Authority of the State of New York (DASNY) and Perkins Eastman Architects, P.C. (Perkins) and that DASNY’s negligence claim against Perkins was duplicative of its breach of contract claim.The Appellate Division denied Perkins’ motion for summary judgment on the City’s breach of contract claim, holding that the City had raised an issue of fact whether it was an intended third-party beneficiary of the parties’ contract and denied Perkins’ motion for summary judgment to dismiss DASNY’s negligence claim as duplicative of its breach of contract claim, holding that there was an issue of fact whether Perkins assumed a duty of care to reform in accordance with professional standards that was independent of its contractual obligations. The Court of Appeals reversed, holding (1) the City failed to raise an issue of fact concerning its status as a third-party beneficiary, and Perkins’ motion for summary judgment on this issue should have been granted; and (2) under the circumstances, the negligence claim was duplicative of the breach of contract cause of action. View "Dormitory Authority of State of N.Y. v. Samson Construction Co." on Justia Law