Justia Contracts Opinion Summaries

The Supreme Court affirmed the judgment of the district court dismissing this lawsuit after its prior decision that a 2006 agreement between the cities of Spring Hill and Olathe was unenforceable as a governmental action that could not bind subsequent city councils, holding that Olathe was not entitled to relief on any of its claims of error.The agreement at issue restricted the cities' future growth by establishing boundaries for annexing land lying adjacent to the two cities. The agreement had no fixed expiration term and stated that termination could occur only upon mutual consent of the parties. In 2021, Olathe filed a petition seeking preliminary and injunctive relief to restrain Spring Hill from annexing certain disputed property. The district court denied the request for injunctive relief and then dismissed the suit. The Supreme Court affirmed, holding that the agreement was an unenforceable attempt to bind future city councils to a governmental policy decision. View "City of Olathe v. City of Spring Hill" on Justia Law

Fountain of praise, a church, leased space to Central Care Integrated Health Services. Shortly after the execution of the lease, the relationship soured when the parties disagreed on the frequency and amount of rent payments. Eventually, Fountain of Praise terminated the lease and successfully evicted Central Care from the premises.Subsequently, Central Care filed for Chapter 11 reorganization. Central Care then sued Fountain of Praise in state court, claiming breach of contract and unjust enrichment. Fountain of Praise then removed the case to bankruptcy court as an adversary proceeding. The bankruptcy court entered judgment in favor of Fountain of Praise, finding that any breach was excusable due to Central Care's failure to make timely rent payments and that Central Care lacked the requisite interest in the property for an unjust enrichment claim.Central Care appealed, and the district court judge assigned to the case reassigned the case to a magistrate judge who affirmed the bankruptcy court's judgment.On appeal, the Fifth Circuit vacated the magistrate judge's order, finding that the district court improperly authorized referral of the appeal from a bankruptcy court decision to a magistrate judge. Under 28 U.S.C. Section 158, appeals from a bankruptcy court must be heard either by the district court or a panel of bankruptcy court judges. View "South Central v. Oak Baptist" on Justia Law

The Supreme Court reversed the order of the district court granting summary judgment in favor of the cities of Pella and Oskaloosa regarding the validity of an agreement between the cities and Mahaska County to establish a regional airport authority, holding that Landowners had standing to challenge the agreement.Landowners brought this action seeking a judgment that the agreement at issue was illegal and an injunction to prevent the transaction. The district court held that Landowners lacked standing to bring the suit and granted summary judgment in favor of the Cities. The Supreme Court reversed, holding (1) by entering into the agreement, the County's Board of Supervisors bound future board to a particular course of legislative action, in violation of the Iowa Constitution; (2) the agreement violated precedent regarding delegation of a municipality's legislative power; and (3) therefore, the district court erred in declaring the agreement to be valid and ordering specific performance by the County of its obligations under the agreement. View "Site A Landowners v. South Central Regional Airport Agency" on Justia Law

The Supreme Court affirmed the order of the district court granting a motion to approve a settlement agreement reached in mediation involving siblings Lily Smith and Sam, Dan, and Vernon Lindemulder, holding that Petitioners were not entitled to relief on their claims of error.The agreement at issue resolved claims involving the Alice M. Lindemulder Trust, established by the parties' mother, which held more than 2,000 acres of land in Stillwater County. Sam appealed the district court's decision to approve the settlement agreement, arguing that the agreement was unenforceable because he lacked the capacity to enter it and had been subjected to undue influence. The Supreme Court affirmed, holding that the district court (1) did not err in concluding that Sam validly consented to the agreement; and (2) did not err in holding that the agreement was valid and enforceable. View "Smith v. Lindemulder" on Justia Law

The First Circuit affirmed the judgment of the district court entering summary judgment in favor of Defendant Thomas Wakefield and dismissing Plaintiff Pleasantdale Condominiums LLC's claims alleging nondisclosure of material information under a Maine statute, holding that Defendant was entitled to summary judgment as a matter of law.After it purchased an apartment complex Plaintiff sued Defendant, the seller, alleging claims for fraud and negligent misrepresentation. Both counts were based on the alleged violation of Me. Rev. Stat. Ann. tit. 33, 173(5). The district court concluded that Defendant was entitled to summary judgment on both counts. The First Circuit affirmed, holding that Defendant was entitled to summary judgment as a matter of law on Plaintiff's claim for fraud in the nature of active concealment. View "Pleasantdale Condominiums, LLC v. Wakefield" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the order of the district court concluding that Plaintiff was entitled to "reasonable attorney's fees" on appeal from a decision of the magistrate in Plaintiff's favor, holding that there was no error.The trial court awarded the attorney's fees at issue in this action seeking the recovery of money Defendant owed Plaintiff under a contract to purchase real estate that obligated Defendant, the buyer, to pay Plaintiff, the seller, a due diligence fee and an earnest money deposit. The court of appeals affirmed the attorney's fee award. The Supreme Court affirmed, holding that Defendant's allegations of error were unavailing. View "Reynolds-Douglass v. Terhark" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the determination of the circuit court that the security agreement between Harvey Haynes, the debtor, covered future advances made by Farmers Tobacco Warehouse (Farmers) so as to have priority over the security interest claimed by Versailles Farm Home and Garden, LLC (Versailles) in Haynes' 2013 tobacco crop, holding that there was no error.In 2014, Versailles brought this action against Haynes to collect on the balance due under the agreement. Versailles joined Farmers as a party to assert its claim against Farmers for conversion to the extent Farmers retained any proceeds in excess of the amount Haynes owed. Farmers admitted selling a portion of Haynes' 2013 tobacco crop and retaining the proceeds but denied doing so in violation of Versailles' security interest. The trial court granted Versailles' motion for summary judgment against Haynes and then granted Farmers' motion for summary judgment as to its cross-claim against Haynes asserting a first and superior lien in Haynes' 2013 tobacco crop. The Supreme Court affirmed, holding that the trial court did not err. View "Versailles Farm Home & Garden, LLC v. Haynes" on Justia Law

The Supreme Court affirmed the decision of the court of appeals that a real property contract entered into by Henry Gray and William, Mary and Frank Stewart in this case was unenforceable under the statute of frauds but held that this decision did not apply equally to William, Mary and Frank.Henry entered into a real estate contract with Frank, his brother William, and William's wife, Mary. Later, Henry filed a complaint against Frank, William and Mary alleging breach of contract and requesting specific performance and damages. The trial court entered judgment in favor of Henry and awarded $19,286 in damages. The court of appeals reversed in part. The Supreme Court affirmed, holding (1) the contract at issue did not satisfy the statute of frauds; (2) the trial court's findings of fact may not serve as a basis to reverse the court of appeals' decision as to William and Mary; and (3) the court of appeals did not err when it reversed the trial court's damage award. View "Gray v. Stewart" on Justia Law

The Supreme Court answered certified questions seeking to clarify whether, in payment of royalties under an oil and gas lease, the lessor may be required to bear a portion of the post-production costs incurred in rendering the oil and gas marketable.Specifically, the district court asked whether Estate of Tawyne v. Columbia Natural Resources, LLC, 633 S.E.2d 22 (W. Va. 2006) is still good law in West Virginia and then asked the Supreme Court to expound upon its holding in Tawney. The Supreme Court answered (1) Tawney is still good law; and (2) this Court defines to answer the reformulated question of what level of specificity Tawney requires of an oil and gas lease to permit the deduction of post-production costs from a lessor's royalty payments. View "SWN Production Co., LLC v. Kellam" on Justia Law

Plaintiff Terri Anderson appealed the grant of summary judgment entered in favor of the defendants. At issue was an agreement to purchase certain residential property located on Ono Island in Baldwin County, Alabama ("the property") for $1.4 million. In 2012, Robert Bowling III acquired the property and executed a promissory note in favor of Merchants Bank. Merchants Bank subsequently assigned the promissory note and its mortgage interest in the property to Wells Fargo Bank ("Wells Fargo"). In 2018, Bowling conveyed his interest in the property to Robin and Michael Coleman via a vendor's lien deed. The Colemans executed a promissory note evidencing a debt to Bowling. In 2020, the Colemans conveyed a partial interest in the property to their friends, France Frederick and Thomas Sparks. In March 2021, the Colemans, Frederick, and Sparks entered into a purchase agreement regarding the property with Anderson. In April 2021, the sellers decided they had made a mistake by agreeing to sell the property. Robin Coleman eventually sent a communication to Anderson's realtor explaining, in relevant part: "We have voided the contract you sent us and have decided to keep our property." Anderson then initiated this action seeking an injunction prohibiting the sellers from violating the terms of the purchase agreement and a judgment requiring specific performance under the terms of the purchase agreement or, as an alternative to specific performance if the court were to determine that such relief was unavailable, damages for breach of contract. The sellers moved to dismiss Anderson's complaint, arguing that title to the property was unmarketable due to Bowling's and Wells Fargo's respective unsatisfied interests in the property. Accordingly, they contended, the language of the purchase agreement required a refund to Anderson of her earnest-money deposit and an automatic termination of the purchase agreement. The Alabama Supreme Court held only that the sellers could not invoke the marketability requirement of the termination provision set out in the purchase agreement to unilaterally rescind the purchase agreement under the circumstances presented by the record because it appeared that Anderson was willing to waive marketability of the sellers' title to the property to purchase whatever interest they were able to convey and because the sellers have expressly agreed to sell their interest in the property to Anderson, provided that the other pertinent contingencies of the purchase agreement were met. Judgment was reversed and the case remanded for further proceedings. View "Anderson v. Coleman, et al." on Justia Law