Justia Contracts Opinion Summaries

The Minnesota Supreme Court reversed a decision by the Court of Appeals, ruling that the district court did not abuse its discretion in certifying an order as a final partial judgment under Minnesota Rule of Civil Procedure 54.02. The case arose from a dispute between the City of Elk River and Bolton & Menk, Inc. over a large construction contract for a wastewater treatment plant improvement project. The City sued Bolton for alleged breach of contract and professional negligence. Bolton responded by filing a third-party complaint against three other parties involved in the contract. The district court dismissed Bolton's third-party complaint and Bolton sought to have the dismissal order certified as a final judgment for immediate appeal. The district court granted this certification, but the Court of Appeals dismissed Bolton's appeal, determining that the district court had abused its discretion in certifying the order as a final judgment. The Minnesota Supreme Court disagreed, finding that the district court had offered valid reasons for its certification, including that the third-party claims presented distinct issues from the principal claims and that the case was in its early stages at the time of certification. The Supreme Court therefore reversed the decision of the Court of Appeals and remanded the case for further proceedings. View "City of Elk River vs. Bolton & Menk, Inc." on Justia Law

In this case, the Supreme Court of the State of Idaho upheld a lower court's summary judgment in favor of the defendants, George and Jesse’s Les Schwab Tire Store, Inc., and two of its owners, Bruce and Richard Byram. The plaintiff, Adam Davis, had been employed as an assistant manager at Les Schwab from April 2016 till June 2019. In March 2019, there was a shortage in the cash deposits and surveillance footage showed Davis bending down out of camera view in the area where the cash deposits were kept while he was alone in the store. This led to Davis being arrested and charged with grand theft, and his employment was terminated. Although the charges against Davis were later dropped, he sued the defendants for breach of his employment contract, false arrest, defamation per se, and for knowingly giving a false report to the police. The district court granted the defendants’ motion for summary judgment on all of Davis’s claims. The Supreme Court affirmed the lower court's decision, finding no genuine issue of material fact that could support Davis’s claims. The court found that Davis was an at-will employee who could be terminated without cause and that there was no evidence to show that the defendants had acted with malice. The court also found that the plaintiff's attorney had violated Rule 11.2 by submitting arguments that were not well grounded in fact, and awarded a portion of the defendants' attorney fees to be paid by the plaintiff's counsel. View "Davis v. George and Jesse's Les Schwab Tire Store, Inc." on Justia Law

The Supreme Court reversed the judgment of the district court denying Wind River Rehabilitation and Wellness's motion to compel arbitration in this action alleging medical malpractice, holding that the district court erred in denying the motion to compel arbitration.Plaintiff, the wrongful death representative of Loy Forshee, filed this action against Wind River, where Forshee lived when he fell and broke his hip, alleging medical malpractice. Wind River moved to compel arbitration under the parties' arbitration agreement. The district court denied the motion, concluding that Wind River waived his right to arbitration by waiting fourteen months to compel arbitration. The Supreme Court reversed, holding that the record did not support a conclusion that Wind River waived its right to arbitrate. View "Empres at Riverton, LLC v. Osborne" 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

The Supreme Court quashed the decision of the superior court granting Defendant's motion to compel production of a complete, unreacted copy of a settlement agreement between Plaintiffs and the former codefendants who settled Plaintiffs' claims, holding that the trial justice abused her discretion in granting Defendant's motion.In granting Defendant's motion to compel production, the trial justice concluded that the amount paid in accordance with the settlement agreement was not discoverable "pursuant to Rhode Island and federal law." When Plaintiffs failed to comply with the order the superior court granted Defendant's motion to dismiss. The Supreme Court quashed the decision below and remanded the case, holding that the trial justice abused her discretion in granting Defendant's motion to compel production of a complete, unreacted copy of the settlement agreement. View "Noonan v. Sambandam" on Justia Law

The Supreme Court affirmed the judgment of the circuit court awarding attorneys' fees after a medical doctor sued and lost against a hospital following its revocation of the doctor's medical staff and surgical privileges, holding that the circuit court did not err or abuse its discretion.Doctor, a surgeon, sued Hospital after his termination stemming from allegations that Doctor provided care that fell short of standard surgical practice. After a remand, all of Doctor's claims were dismissed. Thereafter, the circuit court awarded Hospital attorneys' fees and costs. The Supreme Court affirmed, holding (1) the motion for attorneys' fees was timely filed; and (2) Doctor was not entitled to relief on his remaining allegations of error. View "Williams v. Baptist Health" on Justia Law

Law firm Halscott Megaro, P.A. (“Halscott Megaro” or “the firm”) sued former clients and their guardians (collectively “former clients”), seeking to recover unpaid legal fees and expenses. A district court dismissed the action under Federal Rule of Civil Procedure 12(b)(6). The district court took judicial notice of a North Carolina State Bar Disciplinary Hearing Commission (“Commission”) decision that found the firm’s lead partner misled the former clients and engaged in other unethical conduct. The court then held the firm was precluded from relitigating issues decided by the Commission. It held that Halscott Megaro failed to plausibly plead claims for which relief could be granted. Halscott Megaro appealed, arguing the district court improperly considered matters outside the pleadings and failed to accept its allegations and all reasonable inferences from them as true in concluding that the Commission’s decision as to its lead partner bound the law firm.   The Fourth Circuit affirmed and held that the district court committed no reversible error in granting the former clients’ motion to dismiss or in denying the law firm’s motion for recusal. The court wrote that it agreed with the district court’s conclusion that the Commission was acting in a judicial capacity when it entered its discipline order against Megaro. The court also agreed that Megaro received a full and fair opportunity to litigate the issues and due process protections. Further, the court held that the firm’s allegations of impartiality were not related to any particular facts, sources or statements. A presiding judge is not required to recuse himself simply because of unsupported or highly tenuous speculation. View "Halscott Megaro, P.A. v. Henry McCollum" on Justia Law

The Supreme Court reversed the order of the district court granting summary judgment in favor of Defendant on her counterclaim for breach of contract in this legal malpractice lawsuit, holding that there was a genuine issue of material fact as to whether the parties entered into a lawfully enforceable settlement agreement.The underlying lawsuit arose after the death of Plaintiff's mother when Defendant failed timely to file an application with the Wyoming Medical Review Panel and a wrongful death lawsuit. Defendant filed a counterclaim for breach of contract, alleging that the parties had entered into a valid agreement to settle the legal malpractice claim for $100,000. The district court granted summary judgment in favor of Defendant, concluding that the settlement agreement was enforceable. The Supreme Court reversed, holding that there was a genuine issue of material fact about whether the parties had a setting of the funds on the issue of who was settling and who would be bound by the settlement, precluding summary judgment. View "Kappes v. Rhodes" on Justia Law

Plaintiff Sean Kelly appealed the grant of summary judgment to the University of Vermont Medical Center (UVMMC) on employment discrimination and breach-of-contract claims arising from UVMMC’s decision not to extend his one-year medical fellowship. UVMMC selected plaintiff for the 2017-18 fellowship. UVMMC was aware that plaintiff suffered from an adrenal deficiency that had delayed the completion of his residency. In the first five months of the fellowship, plaintiff missed nineteen full days and parts of nine more days for various reasons. By February 2018, after missing several more days and expressing that he felt “frustrated with [his] absences” and “overall inadequate as a fellow,” program personnel became concerned that plaintiff was falling behind in his training. In a March 30 meeting, the program director told plaintiff his performance had “deficiencies and these need[ed] to be addressed.” At some point during this period, the director also told plaintiff he “should plan on extending [his] fellowship due to [his] time out and some minor deficits through August.” Plaintiff emailed other program personnel expressing frustration at the prospect of staying through August to complete his training. On April 14, 2018, plaintiff suffered a stroke, and on April 19th he attempted suicide. He was hospitalized from April 14 through May 3 and was not cleared to return to work until June 1, 2018. In all, plaintiff missed approximately six more weeks of the fellowship. On or about May 31, the director called plaintiff and told him that while UVMMC had determined he needed six more months of training to finish the fellowship, it could not accommodate additional training for that length of time. UVMMC paid plaintiff his remaining salary. Plaintiff filed a grievance under the Graduate Medical Education rules; the grievance committee affirmed UVMMC's decision. Because the decision not to extend his fellowship was an academic decision, there was no employment action and consequently no adverse employment action. The Vermont Supreme Court did not find plaintiff's arguments on appeal persuasive, and affirmed the grant of summary judgment in UVMMC's favor. View "Kelly v. University of Vermont Medical Center" on Justia Law

Cal-Am, a developer and operator of RV and mobile-home parks leased the Yuma Sundance RV Resort from its owner, intending to construct a new banquet and concert hall on the property. The property owner provided the funding for the construction. Cal-Am managed the project. Cal-Am hired a contractor, Nickle, to design and construct the hall, who then hired Edais Engineering to survey the property and place construction stakes to mark the Hall’s permitted location. No contract existed between Edais and Cal-Am. Edais acknowledges that its placement of the stakes was defective. Cal-Am was forced to adjust its site plan, eliminating eight RV parking spaces. Cal-Am sued Edais for claims including negligence. The trial court granted Edais summary judgment on the negligence claim finding that Cal-Am could not recover its purely economic damages. The court of appeals affirmed.The Arizona Supreme Court affirmed, repudiating its 1984 Donnelly Construction holding that a design professional’s duty to use ordinary skill, care, and diligence in rendering professional services extends both to persons in privity with the professional and to persons foreseeably affected by a breach of that duty. Under Arizona’s current framework, which repudiated foreseeability as a basis for duty, design professionals lacking privity of contract with project owners do not owe a duty to those owners to reimburse purely economic damages. View "Cal-Am Properties, Inc. v. Edais Engineering, Inc." on Justia Law