Justia Contracts Opinion Summaries

After suffering a stroke, Mary, a member of the Brentwood Hutterite Brethren, received care at a Select Specialty Hospital. During her time at Select, she was covered by Brentwood’s insurance. But after Mary applied for and received Medicaid, it retroactively covered her time at Select. Select accepted $300,000 from Medicaid for Mary’s care—far less than it was expecting from Mary’s Brentwood insurance. Select sought payment from Brentwood, the Hutterite Brethren General Fund (the Fund), and South Dakota Medical Holdings Company (Dakotacare) for breach of contract. It also sought damages from Brentwood and the Fund for fraud and deceit. The district court granted summary judgment to Brentwood, the Fund, and Dakotacare. On appeal, Select argues that Brentwood and the Fund breached their contractual obligations by refusing to pay for Mary’s treatment.   The Eighth Circuit affirmed. The court explained that Select has already accepted money from Medicaid “as payment in full” for Mary’s care. Under 42 C.F.R. Section 447.15, “the Medicaid agency must limit participation in the Medicaid program to providers who accept, as payment in full, the amounts paid by the agency.” The court wrote that as a Medicaid program participant, Select must follow this regulation. The central issue here is whether Section 447.15’s “payment in full” provision bars Select from pursuing third parties like Brentwood and the Fund after accepting payment from Medicaid. The court wrote that in its view, Section  447.15’s “payment in full” language is plain and unambiguous: Once Select accepted payment from Medicaid, it was paid in full for Mary’s care. View "Select Specialty Hospital v. Brentwood Hutterian, Brethren" on Justia Law

The Supreme Court affirmed the judgment of the trial court granting Defendant's motion to dismiss the underlying complaint filed by Port of Louisville for defamation and professional malfeasance, holding that Port of Louisville had no legally recognized relationship with R. Wayne Stratton, CPA and Jones, Nale & Mattingly PLC (collectively, Stratton), and therefore, Stratton did not owe the Port of Louisville any duty.Louisville and Jefferson County Riverport Authority filed a lawsuit seeking to terminate Port of Louisville's lease based on allegations that Port of Louisville breached the parties' lease The action was stayed while the claims were referred to an arbitrator, who found that Port of Louisville had not breached the lease. Based on what occurred during the arbitration the Port of Louisville brought a complaint against Stratton for defamation and professional malfeasance. The trial court granted Stratton's motion to dismiss, and the court of appeals affirmed. The Supreme Court affirmed, holding that Port of Louisville had no legally recognized relationship with Stratton that would cause Stratton to owe it a duty. View "New Albany Main Street Properties, LLC v. R. Wayne Stratton, CPA" on Justia Law

In January 2021, many customers of the online financial services company Robinhood were aggressively buying specific stocks known as “meme stocks” in a frenzy that generated widespread attention. Robinhood suddenly restricted its customers’ ability to buy these meme stocks (but not their ability to sell them). Some Robinhood customers who could not buy the restricted stocks brought this putative class action, seeking to represent both Robinhood customers and all other holders of the restricted meme stocks nationwide who sold the stocks during a certain period. As Robinhood customers, they allege that they lost money because Robinhood stopped them from acquiring an asset that would have continued to increase in value.   The Eleventh Circuit affirmed the district court’s dismissal of the claims. The court explained that Plaintiffs failed to state a claim. The court explained that its contract with Robinhood gives the company the specific right to restrict its customers’ ability to trade securities and to refuse to accept any of their transactions. Thus, the court wrote that because Robinhood had the right to do exactly what it did, Plaintiffs’ claims in agency and contract cannot stand. And under basic principles of tort law, Robinhood had no tort duty to avoid causing purely economic loss. View "Andrea Juncadella, et al v. Robinhood Financial LLC, et al" on Justia Law

Petitioners Infinity Select Insurance Company and Infinity Property and Casualty Corporation (collectively, Infinity) are named Defendants in a pending action (the instant lawsuit). The instant lawsuit stems from an earlier 2013 case (the prior action) in which plaintiffs sued Infinity’s insured for negligence and wrongful death in connection with a three-vehicle collision (the collision). In August 2022, the court issued its ruling. The primary effect of the ruling was to reform the Infinity policy to provide greater bodily injury policy limits of $750,000. Per its terms, the ruling “establishes the policy limits for the jury’s consideration in the upcoming jury trial on the remaining causes of action” including plaintiffs’ cause of action against Infinity for bad faith breach of the implied covenant of good faith and fair dealing due to Infinity’s rejection of plaintiffs’ Code of Civil Procedure section 998 demand of $750,000. Infinity filed a petition for a writ of mandate challenging the subject ruling.   The Fifth Appellate District concluded that the trial court erred in reforming the Infinity policy. The court held that the motor carrier of property—not the insurer—bears ultimate responsibility for meeting the requirements necessary to obtain a motor carrier permit. Moreover, even where an insurer intends to issue and certify a policy under section 34631.5, it is not obligated to issue the policy in the full amount of $750,000. Additionally, the court wrote evidence of insurance is not the only means of complying with the MCPPA financial responsibility requirements and infinity was under no duty to determine whether the insured had otherwise complied with MCPPA requirements. View "Infinity Select Ins. Co. v. Super. Ct." on Justia Law

Following a shooting at a bar in downtown St. Louis, Missouri, Plaintiff, who was injured as a bystander, obtained a $2.5 million judgment against the bar’s owner and operator, Steven Scaglione. Plaintiff thereafter filed this equitable-garnishment claim against Scaglione and his insurer, Acceptance Indemnity Insurance Company (Acceptance). Scaglione filed cross-claims against Acceptance, alleging that it had, in bad faith, failed to defend or indemnify him and breached its fiduciary duty. Acceptance filed motions to dismiss both Plaintiff’s and Scaglione’s claims, which the district court granted based on the applicability of an assault-and-battery exclusion in Scaglione’s policy. In this consolidated appeal, both Plaintiff and Scaglione assert that the district court erred in dismissing their claims. 
 The Eighth Circuit affirmed. The court explained that the district court did not suggest that the assault-and-battery exclusion did not apply solely because the purported victim was not the target. Accordingly, the court rejected this argument and concluded that the unambiguous policy language covers claims of injuries sustained by innocent bystanders arising out of an assault and battery. The court thus concluded that the policy exclusion applies. Further, the court concluded that Scaglione’s negligence was not independent and distinct from the excluded assault and battery. The court explained that the concurrent-proximate-cause rule thus does not apply, and, therefore, the exclusion bars coverage under the policy. Without coverage, Plaintiff and Scaglione cannot state a claim. The district court thus did not err in granting the motions to dismiss. View "Steven Scaglione v. Acceptance Indemnity Ins Co" on Justia Law

In this insurance dispute, the Supreme Court held that Ariz. Rev. Stat. 20-259.01 mandates that a single policy insuring multiple vehicles provides different underinsured motorist (UIM) coverages for each vehicle rather than a single UIM coverage that applies to multiple vehicles.Plaintiff's mother died in a car crash caused by a neglectful driver. Plaintiff submitted a UIM to CSAA General Insurance Company, her mother's insurer. At the time of the accident, Plaintiff's mother's CSAA policy covered the mother's two vehicles and provided UIM coverage of $50,000 per person. When CSAA paid only $50,000 Plaintiff sought an additional $50,000 under an "intra-policy stacking" theory. After CSAA rejected the claim, Plaintiff sued for declaratory judgment, alleging breach of contract, bad faith, and a class action. CSAA moved to certify two questions. The Supreme Court answered (1) insurers seeking to prevent insureds from stacking UIM coverages under a single, multi-vehicle policy must employ section 20-259.01(H)'s sole prescribed method for limiting stacking; and (2) section 20-259.01(B) does not bar an insured from receiving UIM coverage from the policy in an amount greater than the bodily injury or death liability limits of the policy. View "Franklin v. CSAA General Insurance" on Justia Law

Kendall Hunt Publishing Company (Kendall Hunt) filed suit against The Learning Tree Publishing Corporation (Learning Tree) in district court in Iowa, where Kendall Hunt is located. The complaint alleged, as relevant here, claims of copyright infringement, tortious interference with contract, and unfair competition. The district court1 granted Learning Tree’s motion to dismiss for lack of personal jurisdiction, concluding that the California corporation lacked minimum contacts with Iowa.   The Eighth Circuit affirmed. The court wrote that Learning Tree’s contacts with Iowa were as follows: it maintains a nationally available website through which an Iowa resident purchased the allegedly infringing work. This conduct was not “uniquely or expressly aimed at” Iowa, however, particularly in light of the fact that Learning Tree did not advertise in Iowa and its litigation-anticipated sale to a Kendall Hunt employee occurred in Iowa. Although Kendall Hunt argued in its brief that this online sale was sufficient to create jurisdiction in Iowa, our court subsequently decided on similar facts that a single online sale did not establish personal jurisdiction over Defendant. The remaining specific-jurisdiction analysis factors do not tip the balance in Kendall Hunt’s favor. The court concluded that because Learning Tree’s connections with Iowa were not such that it would reasonably have anticipated being haled into court there, the district court lacked personal jurisdiction over the corporation. View "Kendall Hunt Publishing Company v. The Learning Tree Publishing Corporation" on Justia Law

The Supreme Court affirmed the judgment of the circuit court in this appeal concerning damage caused to an airplane owned by Plaintiff, holding that this Court had jurisdiction and that there was no error in the damages award and decision to award prejudgment interest.In the first appeal in this negligence case the Supreme Court remanded the case for a new trial on the limited issue of damages on the ground that the circuit court prejudicially erred in instructing the jury on damages. On remand, the court awarded Plaintiff $131,735 in damages, prejudgment interest, and costs. The Supreme Court affirmed, holding (1) this Court had appellate jurisdiction; (2) the circuit court did not err in the method it chose to calculate Plaintiff's damages; and (3) the circuit court did not err in awarding prejudgment interest. View "Wright v. Temple" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court determining that Plaintiff could not recover under a commercial general-liability (CGL) insurance policy issued by United Specialty Insurance Company, holding that when a CGL insurance policy excludes coverage for injuries arising out of an "assault or battery," the subjective intent of the person who committed the assault or battery is irrelevant.Brown County Care Center, an adult care facility, contracted with United for CGL insurance. The policy excluded coverage for bodily injury arising from "any actual, threatened or alleged assault or battery." Plaintiff was living at the Center when he was attacked by another resident, who was later found by the trial court to be not guilty of felonious assault by reason of insanity. Plaintiff sued, and he and the Center entered into a settlement. Plaintiff later brought a declaratory judgment action against United to collect on the judgment. The trial court determined that Plaintiff could not recover under the policy. The court of appeals reversed. The Supreme Court reversed, holding (1) the attack on Plaintiff qualified as a civil-law assault; and (2) because the policy excluded coverage for bodily injuries arising for civil assaults the trial court did not err in its judgment. View "Krewina v. United Specialty Insurance Co." on Justia Law

The Supreme Judicial Court held that in the instant cases, where the decedents had no right to bring a cause of action for the injuries that caused their deaths at the time that they died as a result of the running of the statute of limitations on the decedents' underlying tort and breach of warranty claims, Plaintiffs, as personal representatives of the decedents' estates, had no right to bring wrongful death actions based on those injuries.The Supreme Judicial Court affirmed the judgments of the lower courts dismissing these separate actions for wrongful death under Mass. Gen. Laws ch. 229, 2. Both superior court judges ruled that, because wrongful death recovery is derivative of a decedent's own cause of action, the underlying wrongful death claims were precluded, as each decedent could not have brought claims based on the injuries that caused his death had he survived. The Supreme Judicial Court affirmed, thus following the majority approach precluding recovery for wrongful death where the statute of limitations on the decedent's underlying claims ran before the decedent's death. View "Fabiano v. Philip Morris USA Inc." on Justia Law